Colorado Might Ban SSN Requirements for Unpaid Internships and Clinicals

The Bottom Line

If you're a nursing student or an unpaid intern without a Social Security Number, getting your required clinical hours just got easier. This bill prevents nonprofits, schools, and hospitals from demanding an SSN for non-employment background checks, requiring them to accept an ITIN or fingerprinting instead so talented people aren't blocked from advancing their education.

What This Bill Actually Does

Many degree programs, internships, and volunteer positions require a routine background check before you can start. Usually, the default form asks for a Social Security Number (SSN). But what happens if you don't have one—perhaps because you're an international student or an undocumented resident? Under current practices, you get stuck. You can't pass the check, which means you can't complete your required clinical hours, finish your internship, or get your degree, even if you are otherwise perfectly qualified and pose zero safety risk.

HB26-1143 changes the default. It requires certain organizations to accept an Individual Taxpayer Identification Number (ITIN) in place of an SSN when running background checks for non-employment educational opportunities. This covers unpaid internships, pre-apprenticeships, volunteer gigs, and required clinical rotations for health-related degrees. Alternatively, these groups can run fingerprint-based checks, which don't require an SSN but still thoroughly vet a person's criminal history through the Colorado Bureau of Investigation. The law specifically applies to state colleges, K-12 schools, 501(c)(3) nonprofits, and healthcare facilities (including hospitals, urgent care centers, retail clinics, and telemedicine providers).

The bill also includes several common-sense carve-outs so organizations don't run afoul of other laws. Entities can still require an SSN if it is explicitly mandated by state or federal law, required by a grant, necessary to process reimbursements, or if the intern will be handling bank accounts where financial institutions legally require an SSN to verify identity. If an organization simply refuses to comply and rejects an ITIN without a valid exemption, the state Attorney General can step in and levy a $2,000 civil penalty for a first offense and $5,000 for subsequent violations.

What It Means for You

For Colorado students, career switchers, and volunteers, this is a massive sigh of relief if you or someone in your family relies on an ITIN instead of a Social Security Number. We are primarily talking about young professionals trying to get a foothold in high-demand fields like nursing, teaching, or specialized trades. Before this policy, you could spend thousands of dollars and years of your life passing exams, only to hit a brick wall when a hospital or school demanded an SSN just to run a standard background check for your required practicum.

If you're an applicant in this situation, you now have clear legal backing to provide your ITIN for non-paid educational roles. Keep in mind, you will still need to pass the actual background check—this policy does not lower any safety or criminal history standards; it just changes the ID number used to run the search. Here is a quick look at what is covered under this new rule:

• Unpaid clinical experiences required for graduation or licensure (especially in health-related programs)
• Unpaid internships and volunteer roles at 501(c)(3) nonprofits
• Pre-apprenticeships that don't classify as traditional employment

It is incredibly important to note that this applies only to non-employment educational opportunities. If you are applying for a paid, W-2 job, the employer is still subject to standard federal and state employment laws that require an SSN. Additionally, if your unpaid internship involves handling money or being reimbursed for travel expenses, the organization might still legally need to ask for an SSN due to federal banking or tax rules. It is smart to keep both an ITIN and alternative documentation ready, and calmly remind program coordinators of the new rules if you hit unexpected resistance.

What It Means for Your Business

If you run or manage operations for a 501(c)(3) nonprofit, a private or public school, a hospital, a clinic, or a telemedicine practice, this bill directly impacts how you onboard your unpaid talent. You can no longer rely on a rigid "SSN-only" policy for background checks on volunteers, interns, pre-apprentices, or clinical students. You need to review your onboarding software, application forms, and third-party background check vendors to ensure they can process an Individual Taxpayer Identification Number (ITIN) or utilize a fingerprint-based background check instead.

The penalties for dragging your feet on this update are steep. The Colorado Attorney General is tasked with enforcement, and non-compliance carries a $2,000 civil penalty for the first violation and $5,000 for every violation after that. If your automated HR software automatically rejects five nursing applicants because they left the SSN field blank, you could be looking at a hefty fine right out of the gate. You should sit down with your HR team and legal counsel to map out exactly which of your roles are strictly unpaid educational opportunities versus actual employment, as W-2 jobs are exempt from this and still require standard federal documentation.

Thankfully, there is no need to panic if you operate with strict compliance or grant requirements. The law provides clear exceptions where you are still legally allowed to ask for an SSN. These include:

• When an SSN is required by a specific state or federal law
• When a governmental or accreditation organization's mandatory compliance program requires it
• To comply with the terms of a federal or state grant
• To process expense reimbursements (if tax law requires an SSN for the transaction)
• If the individual will be signing checks or engaging in financial transactions where your bank demands an SSN to verify their identity

It is highly recommended that you document exactly why an SSN is required for any specific unpaid role. Having a clear, legally sound paper trail will protect you if an applicant—or the Attorney General—questions your onboarding practices.

Follow the Money

From a state budget perspective, this bill is essentially a non-event. The official fiscal note shows zero required appropriations. The Department of Law (Attorney General's Office) and the Colorado Department of Public Safety (CDPS) will absorb any extra workload—like enforcement actions or processing a slight uptick in fingerprint background checks—within their existing budgets.

There are two main financial ripple effects. First, any fines collected from organizations that violate the law (the $2,000 to $5,000 penalties) will be funneled directly into the state's Immigration Legal Defense Fund. Second, because some applicants will now use fingerprint background checks instead of name-and-SSN checks, the state will collect a few more background check fees. For context, a fingerprint check costs $39.50, most of which goes to the CBI Identification Unit Cash Fund, with $10 passed along to the federal government. For local school districts and law enforcement agencies, the only real cost is a minimal bump in administrative workload to update their internal policies and forms.

Where This Bill Stands

HB26-1143 is currently Signed Into Law. The latest official action came on 06/03/2026: Governor Signed.

That means the legislative process is complete and the bill is now law. The remaining questions are about implementation timing and how agencies, businesses, or local governments respond.