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AI Compliance DocumentsIn effect: January 1, 2026

Texas TRAIGA (HB 149) · Already in effect — January 1, 2026

Texas AI Law Covers
Every Business. No Exceptions.

Texas HB 149 — the Responsible AI Governance Act — took effect January 1, 2026. No high-risk carveout. No small-business exemption. No revenue threshold. If you use AI in Texas, you are in scope right now.

Built from the enrolled HB 149 bill text on capitol.texas.gov. Not summaries. Not paraphrases. Not training data.

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Instant downloadStatute-citedNIST AI 600-1 aligned

$80K–$200K

per uncurable violation
HB 149 § 552.105(a)

$2K–$40K/day

continuing violations
HB 149 § 552.105(a)

AG Only

no private right of action
HB 149 § 552.101

Deep Dive — How the Law Actually Works

Texas HB 149 builds in a rebuttable presumption of reasonable care (§ 552.105(c)) — you start with the assumption you acted correctly. The government has to overcome that presumption, not the other way around.

The safe harbor (§ 552.105(e)) requires substantial compliance with NIST AI 600-1 or an equivalent recognized framework. NIST AI 600-1 is NIST's framework specifically designed for generative AI risk management — more targeted than the general AI RMF 1.0.

Before enforcement action, the business receives notice and has 60 days to cure curable violations (§ 552.104). Uncurable violations carry a floor of $80,000 — four times Colorado's maximum first-offense penalty.

The law distinguishes developers (who build AI systems) from deployers (who use them). Both have obligations, but they are different obligations with different documentation requirements.

Here's what's actually different about Texas.

Texas signed HB 149 — the Responsible Artificial Intelligence Governance Act — on June 22, 2025. It took effect January 1, 2026. There is no delay period, no extended phase-in. If you use AI in Texas, you are operating under this law today.

Colorado's SB 24-205 uses a “high-risk” classification — if your AI system doesn't meet the definition of high-risk, you're largely outside the law's scope. Texas doesn't do that. TRAIGA applies to any AI system, and to two categories of business: developers and deployers. No carveout. No threshold.

The Law Is Already In Effect

January 1, 2026 has passed. The AG's complaint portal goes live by September 1, 2026 (§ 552.102). Once it does, consumer complaints will have a direct path to enforcement review. The window between now and then is not a grace period — it is time to build your compliance program before complaints arrive.

Does this apply to you?

If you answer “yes” to any of these, TRAIGA covers your business. There is no minimum size, revenue floor, or employee threshold.

Self-assessment: Does Texas TRAIGA apply to you?

There Is No Small-Business Exemption

Unlike Colorado's 50-employee partial exemption, TRAIGA has no size-based carveout. A company with five employees that uses an AI-powered tool to screen job applicants is a deployer under this law with the same obligations as a Fortune 500 company. The only safe harbor is for federally insured financial institutions subject to federal AI oversight (§ 552.056(e)).

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7 Documents. Both Developer and Deployer Obligations.

Each document maps to specific sections of HB 149 (Tex. Gov't Code Ch. 552) and aligns with the NIST AI 600-1 safe harbor standard.

1

AI System Inventory & Classification

HB 149 Enrolled Text

Unlike Colorado, there is no high-risk filter. Any AI system in your Texas operations is in scope. This document is how you know what you have.

2

Risk Management Policy (NIST AI 600-1 Aligned)

§ 552.105(e)

The safe harbor requires substantial compliance with NIST AI 600-1 or an equivalent framework. This policy is the documented foundation that supports the rebuttable presumption of reasonable care.

3

Developer Disclosure Documentation Template

HB 149 Enrolled Text

If you build AI systems and make them available to others, you must give deployers the documentation they need to run their own compliance program. This is that document.

4

Consumer AI Notification Template

HB 149 Enrolled Text

Deployers must notify consumers when they are interacting with or affected by an AI system. The obligation is not limited to high-stakes decisions.

5

Consumer Correction Request Process

HB 149 Enrolled Text

Consumers must have a mechanism to submit corrections or concerns. This document establishes that process and how responses are handled.

6

Bias Evaluation & Anti-Discrimination Documentation

§ 552.056(c)

TRAIGA requires intent for a discrimination violation — disparate impact alone is not enough. Documented good-faith bias evaluation is evidence of that intent, or absence of it.

7

Compliance Checklist

All sections

Every developer and deployer obligation in one place. Cross-referenced to statute sections so you can verify each requirement yourself.

The Rebuttable Presumption — Texas's Safe Harbor

Unlike Colorado's affirmative defense (where you must argue your way out of an accusation), Texas builds in a rebuttable presumption of reasonable care under § 552.105(c). You start with the legal assumption that you acted correctly — the government has to overcome it.

Section 552.105(e) specifies how to lock that presumption in place: substantial compliance with the NIST AI 600-1 (Generative AI Profile) or an equivalent recognized framework. Document it. Keep it current.

Every document in this package is built to the NIST AI 600-1 standard. That is the documented path to TRAIGA's safe harbor.

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Questions we hear a lot.

We're not in Texas. Does this still apply?
If your AI system affects Texas consumers or employees, it likely applies. The law covers AI systems used in Texas operations — the consumer's location matters, not just your company's headquarters. A company based in California that uses AI to screen applicants for Texas jobs is a deployer under TRAIGA.
What's the difference between a developer and a deployer?
A developer creates, trains, or substantially modifies an AI system and makes it available to others. A deployer uses an AI system in a product or service offered to consumers or employees in Texas. Both categories carry real obligations under TRAIGA, but they are different obligations. This package covers both.
We already comply with Colorado SB 24-205. Does that cover Texas too?
Significant overlap exists. Both laws reference NIST frameworks as the path to legal protection, both give the AG exclusive enforcement authority, and both distinguish developers from deployers. But TRAIGA's scope is broader — it covers all AI systems, not just high-risk ones — and the penalty structure is materially different. If you're building for both states, a unified program can satisfy both with targeted additions.
What does the 60-day cure period actually mean?
Before the AG can file an enforcement action, your business must receive written notice of the violation and have 60 days to cure it (§ 552.104). For curable violations, if you fix the problem within that window, enforcement cannot proceed. This is meaningful — but it is not a loophole. The AG can still investigate and build a record during that period. Businesses with real compliance documentation have something concrete to show.
Are these documents legal advice?
No. We are not a law firm. These are compliance templates built from the enrolled statute text — a defensible starting point, not a substitute for legal counsel. A lot of our customers hand these to their attorney for review. That saves their attorney hours of drafting time at $400 an hour.
What about the DIR rulemaking?
Rulemaking authority under TRAIGA sits with the Texas Department of Information Resources (DIR). Our templates address the statutory requirements directly from the enrolled bill text. When DIR publishes rules that affect the compliance requirements, we will update the documents and notify customers.

Verified Against Enrolled Statute Text

Every requirement in these documents traces to a specific section of HB 149. No summaries. No AI-generated legal claims.

Statute-sourced

Built from the enrolled text on capitol.texas.gov

NIST AI 600-1 aligned

Built to the safe harbor standard in § 552.105(e)

Attorney-ready

Hand directly to legal counsel for review

Did You Know? — Quick Facts About TRAIGA

TRAIGA passed the Texas House 146-3 and the Senate 31-0 — one of the most bipartisan AI governance laws ever enacted.

Source: Texas Legislature Online — HB 149 History

A single uncurable violation under TRAIGA can cost between $80,000 and $200,000 — four times Colorado's $20,000 maximum first-offense penalty.

Source: HB 149 Sec. 552.105(a)

TRAIGA creates a 36-month regulatory sandbox allowing companies to test AI systems without a state license — with legal immunity during the testing period.

Source: HB 149 Sec. 553.051

Unlike Colorado's SB 24-205, TRAIGA never uses the term 'high-risk' — its rules apply to any AI system regardless of risk tier.

Source: HB 149 Enrolled Text

Texas preempts local governments from enacting their own AI ordinances — one statewide framework, no patchwork of city rules.

Source: HB 149 Sec. 552.003

The Attorney General's complaint portal goes live by September 1, 2026. Consumer complaints will have a direct path to enforcement review from that date.

Source: HB 149 Sec. 552.102

Sources

  1. Texas Legislature Online — HB 149 Bill History (89th Legislature)
  2. Texas Legislature Online — HB 149 Enrolled Text (Texas Responsible AI Governance Act)
  3. IAPP — Governor Signs Texas Responsible Artificial Intelligence Governance Act
  4. NCSL — Artificial Intelligence 2025 Legislation
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In effect since January 1, 2026

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These documents are compliance templates, not legal advice. We recommend attorney review for your specific situation.