The Colorado Department of Labor and Employment's Division
of Labor Standards and Statistics (the Division) recently adopted
Colorado Overtime and Minimum Pay Standards Order # 36 (COMPS),
which will take effect on March 16, 2020.1 COMPS will replace
the Colorado Minimum Wage Order, which had largely remained
substantively unchanged for two decades. With the adoption of
COMPS, the Division seeks to broadly expand Colorado's
wage-and-hour regulations, limit the reach of exemptions, and
require more complete and accurate payment for all time worked.
The Division spent most of 2019 conducting extensive workplace,
economic, and legal research and began an eight month
pre-rulemaking comment period on March 6, 2019. Over 1,300 people
submitted comments. The commenters spanned nearly all industries
and regions in Colorado, including workers, employers, public
officials, unions, policy analysts, and advocates for both labor
and employers. Given the number of comments
