Colorado's Big Three: How Student Entrepreneurship Counts as Work-Based Learning
Colorado has a new goal for its high schoolers, with a real number attached to it. By the Class of 2029, the state wants every graduating student to leave with at least one of three things: 12 college credits, an industry-recognized credential, or a work-based learning experience. The Colorado Department of Education calls this the Big Three, and as of SB25-315, it comes with state funding behind it, not just a line in a strategic plan.
Two of the three are relatively easy to plan around. College credit is a scheduling question. A credential is a curriculum question. Work-based learning is the hard one, and the state's own data shows why: between 2018 and 2024, Colorado's internship market produced roughly one high-school-accessible posting for every 27 graduates. Nearly 70% of students say they want the experience. The gap isn't interest. It's supply.
What actually counts as work-based learning
CDE defines a qualifying WBL experience narrowly, but the list is broader than most people expect. The approved categories are: clinical experiences, internships, pre-apprenticeships, industry-sponsored projects, registered apprenticeships, on-the-job training, and two categories that don't require an outside employer at all: Supervised Entrepreneurship and School-Based Enterprise.
CDE's own definition of Supervised Entrepreneurship is a student-run business or entrepreneurial experience supported by a mentor or teacher, and its own example is almost a description of a KANU classroom: students running a coffee shop, print shop, bike repair business, or student-led startup, while learning budgeting, operations, and customer service.
That matters because the other WBL categories depend on something outside a school's control: whether a local employer has the capacity to host a student. Entrepreneurship doesn't. A student building a real business under a teacher's supervision qualifies on its own terms, inside the classroom a school already runs.
The 60-hour rule
To count toward the Big Three, a student needs at least 60 cumulative hours in one approved WBL activity during a single academic year, July 1 through June 30. Those hours can accumulate across a fall and spring semester; they don't need to happen in one continuous block.
Sixty hours is a real bar, not a token gesture. It's also worth knowing this is CDE's number for the Big Three specifically, not the same as the separate Perkins V work-based learning standard used for federally funded CTE programs, which suggests a lower minimum and runs through a different agency and reporting system. The two frameworks are related, but a school reporting for the Big Three and a school reporting for Perkins are answering to different rules. Confusing the two is an easy mistake, and one worth avoiding when you're the one explaining it to a board.
Why this is the pathway most schools will struggle with
The credential pathway has a state-maintained list of qualifying certifications. The college-credit pathway runs through existing dual-enrollment infrastructure. Work-based learning runs through employer capacity, and Colorado's own research shows that capacity hasn't kept pace with student demand. Every school heading toward 2029 is going to be looking for a WBL pathway that doesn't depend on finding an outside business willing to host a sixteen-year-old for 60 hours.
Where KANU fits, specifically
KANU is a K-12 platform where students build and run real businesses, real customers, real transactions, inside a course a school already teaches. That puts it inside CDE's Supervised Entrepreneurship and School-Based Enterprise categories, not adjacent to them.
Two things follow from that. First, the hours count without a school needing to secure an outside employer placement. Second, KANU tracks time on task automatically as students work, which gives a school the hour logs and activity dates it needs on hand if a program is selected for monitoring. KANU doesn't file anything to CDE's Data Pipeline on a school's behalf; that reporting is still the school's responsibility. What KANU provides is the underlying evidence, ready when it's time to report it.
This is also, deliberately, not a claim that KANU satisfies Perkins V or a Comprehensive Local Needs Assessment. Those are a separate federal funding mechanism with their own rules, run through a different state office. A school using KANU for its Big Three work-based learning pathway may also be a Perkins recipient, but the two shouldn't be conflated, and we won't pretend otherwise to make a pitch simpler.
What this means heading into 2029
The Big Three isn't a graduation mandate for every diploma in Colorado; it's a state goal, tied to funding, for the Class of 2029. But the funding timeline is real, and the reporting windows are already open. Schools that wait until the year before 2029 to figure out their work-based learning pathway will be competing for the same scarce employer placements as everyone else. Schools that build a Supervised Entrepreneurship pathway now have a WBL experience that scales with their own enrollment, not with how many local businesses happen to have room for an intern.
If you're at CACTE this year and thinking through what your program's WBL pathway looks like heading into 2029, that's exactly the conversation we're here to have.