Travis Bunn

Founder, AppealDesk · Published March 27, 2026 · Updated August 25, 2026

Colorado Only Reassesses in Odd Years. Your Escrow Account Never Gets an Off Year.

Updated August 2026

Colorado reappraises real property on a two-year clock. Assessors set new values in odd-numbered years, mailing the Notice of Valuation by May 1, and the intervening even-numbered year generally just carries that same value forward under C.R.S. Section 39-1-104(10.2). No new notice, no new number, nothing to protest, unless an unusual condition like new construction forces the assessor to take a fresh look. That rhythm means most Colorado homeowners spend half their time in a genuine off year: the assessed value on file hasn't moved since the last reappraisal, and there is no statutory reason for it to.

Your mortgage servicer doesn't work that way. Under Regulation X, 12 CFR 1024.17(c)(3), escrow accounts get analyzed once every twelve months, every single year, odd or even, reappraisal year or not. So in a year when nothing about your assessment changed, your servicer still runs a full analysis cycle, and in a year when your assessment did change, that analysis has no special mechanism for catching a value that's still working its way through an open protest, a County Board of Equalization petition, or a Board of Assessment Appeals case. Two calendars, one running on odd years and one running every year without exception, and the gap between them is where an appeal can quietly outlast Colorado's own reassessment schedule.

What "Over-Assessed" Actually Means in Colorado

Colorado no longer taxes residential property at one flat percentage of its value. Under C.R.S. Section 39-1-104.2, as amended by SB24-233, residential property carries two separate assessed values starting with the 2025 tax year: one for school-district mill levies, valued at roughly 7.15% of actual value, and a lower one, currently 6.25%, for every other local-government levy, including your county, municipality, and special districts. The same house can effectively be assessed at two different percentages depending on which taxing entity is billing you, and the 2026 tax year brings a further value-reduction mechanism under the same law. Don't assume last year's ratio, or your neighbor's, still applies to your bill.

This split is the latest turn in a long-running fight over how Colorado divides the tax burden between homeowners and everyone else. The state used to run this through the Gallagher Amendment, a 1982 rule that locked residential and non-residential property into a fixed statewide 45/55 share of assessed value, which forced the residential assessment rate steadily downward, from 21% in 1986 to 7.15% by 2020, just to hold that ratio as home values outpaced commercial ones. Voters repealed Gallagher in November 2020. SB24-233 is the legislature now setting residential rates directly by statute instead of letting a formula do it, which is exactly why the rate can move again in 2025 and 2026 without a constitutional amendment attached.

Three Levels, and an Off Year in the Middle of Them

If you disagree with your Notice of Valuation, Colorado gives you three places to make your case:

1. County Assessor (Informal protest). File by June 8 under C.R.S. Section 39-5-122, either in writing (postmarked by that date) or in person. The assessor issues a Notice of Determination if the protest isn't resolved outright.
2. County Board of Equalization (CBOE). If you disagree with the assessor's determination, petition the CBOE by July 15 under C.R.S. Section 39-8-106. The board must conclude hearings and issue decisions by August 5 under C.R.S. Section 39-8-107, unless your county has elected an extended schedule running to November 1.
3. Board of Assessment Appeals or District Court. If the CBOE doesn't resolve it, you can escalate to the state Board of Assessment Appeals or file in district court. Both are formal proceedings that run on their own timetable, independent of Colorado's two-year reappraisal calendar.

Notice what isn't on that list: a fourth level tied to the intervening year. If your case is still open at the Board of Assessment Appeals or in district court when an even-numbered year arrives, that year doesn't hand you a new hearing or a fresh notice. It just carries forward whatever value was last on the books, correct or still disputed, because there's no new reappraisal to trigger a second look until the next odd year.

Meanwhile: The RESPA Clock That Doesn't Know What Year It Is

Your escrow account isn't governed by Colorado's reappraisal calendar at all. Under 12 CFR 1024.17(c)(3), your servicer must analyze the account once per twelve-month computation cycle, a cycle set by your loan, not by whether this is an odd or even year in your county. The analysis looks at what the servicer actually paid the county and what it expects to pay next, based on whatever value the county's roll currently shows. It has no field for "protest pending," no field for "CBOE petition filed," and nothing that checks whether this happens to be one of Colorado's off years.

That matters more in Colorado than in states that reassess annually, because in a state with yearly reassessment, next year's notice is at least a fresh chance for the correction to land on the roll. In Colorado, if your case is still open when the intervening year arrives, there is no new notice coming to force the issue. The disputed value simply rolls forward, and so does your servicer's analysis, both indifferent to the fact that a case is still active.

A worked example (hypothetical, not a real case)

Say a homeowner in Jefferson County gets her May 1, 2025 Notice of Valuation on a home the assessor lists at Colorado's median, $472,000. At Colorado's 0.51% effective rate, that pencils out to roughly $2,407 in annual property tax, about $201 a month if spread evenly. (Actual bills depend on local mill levies and which of the two SB24-233 ratios applies, so treat this as illustration, not a quote.) She protests to the assessor by June 8. Denied, she petitions the CBOE by July 15. On August 5, the CBOE grants a partial reduction, down to $450,000, cutting her tax to roughly $2,295 a year, a savings of about $112 a year, or $9 a month. She isn't satisfied and escalates to the Board of Assessment Appeals that fall.

• 2025 (reappraisal year), tax bill: Escrow pays based on the $450,000 CBOE figure. The Board of Assessment Appeals case is still open.
• 2026 (intervening year): No new Notice of Valuation arrives. Under C.R.S. Section 39-1-104(10.2), the county carries forward the $450,000 value, still under dispute, because nothing in the intervening year forces a fresh look while her case is pending elsewhere.
• 2026, escrow analyses: Her servicer still runs its normal twelve-month analysis on schedule. It pays whatever the county bills, based on the carried-forward $450,000, litigation notwithstanding.
• Board of Assessment Appeals decision, mid-2026, a further cut to $420,000: New annual tax roughly $2,142, a total savings of about $265 a year, or $22 a month, measured against the original $2,407.
• Refund and go-forward adjustment: Only happens once the county updates the roll and issues a corrected bill, and her servicer catches it at the next scheduled or requested analysis.

More than a year passes between her original May 2025 notice and a final number, and for most of that stretch the delay had nothing to do with any deadline she missed. It had to do with two separate calendars, Colorado's two-year reappraisal cycle and her servicer's uninterrupted annual analysis, running past each other without ever needing to sync up.

When the Win Finally Reaches Your Escrow Account

Whichever level ultimately rules in your favor, the assessor updates the roll, the county issues a corrected bill, and none of it touches your monthly payment until your servicer sees it. Three federal rules in 12 CFR 1024.17 control what happens once it does:

• The surplus rule. If your next analysis shows a surplus of $50 or more, the servicer must refund it within 30 days, provided you are current on the loan (Section 1024.17(f)(2)(i) and (f)(2)(ii)).
• The cushion cap. Servicers can hold a cushion of no more than one-sixth of estimated annual disbursements, roughly two months' worth (Section 1024.17(c)(5)). A lower tax bill shrinks the allowed cushion too, so a post-appeal refund is often larger than the tax savings alone.
• The off-cycle option. A servicer is permitted, not required, to run an analysis outside its normal annual cycle (Section 1024.17(f)(1)(ii)). Send the county's corrected notice and the new tax bill and ask. There's nothing to lose by asking, since the annual analysis will catch it either way.

Nobody in your servicer's escrow department is tracking your Board of Assessment Appeals docket, and nobody there is keeping a mental note of whether this is one of Colorado's reappraisal years or an off year. The corrected bill from your county assessor is the only document that moves your payment, so keep a copy of the decision and the revised assessment, and send both the moment they arrive, whichever year that happens to be.

Key Counties

The highest-volume appeal jurisdictions in Colorado are Denver, El Paso, Arapahoe, Jefferson, Adams, Douglas, Larimer, and Boulder counties. The statewide June 8 protest deadline, July 15 CBOE petition deadline, and August 5 CBOE decision deadline apply everywhere, but filing portals, local practice, and whether a county has elected an extended CBOE schedule running to November 1 vary by county, so confirm procedure with your specific county assessor before you file.

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