Commerce City, CO Short-Term Rentals: Host Platform Liability (2026)

Section 9-3901 defines a booking service provider as any person or entity that facilitates transactions between a prospective guest and a person or entity offering a short-term rental, a definition broad enough to cover the major online listing and reservation platforms. Section 9-3902(b) then makes it unlawful for any booking service provider to receive payments, directly or indirectly, from an unlicensed short-term rental located in the city, and the Code states that this prohibition is entirely strict liability in nature, meaning the platform's knowledge or intent is not a defense if the underlying rental turns out to be unlicensed.

Section 9-3910(b) adds an ongoing recordkeeping duty: each booking service provider must maintain, for every short-term rental transaction it facilitates in the city over the past five years, the name of the person offering the rental, the rental's address, the dates booked, the price the guest paid and the rental's license number, and section 9-3910(c) makes it unlawful for any person or entity to fail to comply with that recordkeeping section. Because the license number itself must appear in every advertisement under section 9-3908(b), a booking platform has the means to check licensing status before accepting a listing, and the strict-liability standard in section 9-3902(b) puts the compliance burden squarely on the platform rather than only on the host.