AI Compliance for Texas Government Entities
Unlike private companies, Texas state agencies, counties, municipalities, and school districts face affirmative AI mandates: SB 1964 governance duties, HB 3512 training, and TRAIGA disclosure and prohibition rules.
- Sept 1, 2025
- SB 1964 & HB 3512 effective
- HSAI
- binary classification (§ 2054.003(6-a))
- Annual
- review to DIR + certified AI training
- § 552.051
- TRAIGA consumer disclosure duty
SB 1964: The Core Governance Framework
SB 1964 (effective September 1, 2025) is the affirmative AI-governance statute for Texas governmental entities — including hospital districts. Its duties:
- Adopt the DIR ethics code and minimum standards for AI use.
- Classify every AI system under the binary Heightened Scrutiny AI (HSAI) definition (§ 2054.003(6-a)).
- Conduct risk and impact assessments.
- Provide standardized notices (with a hospital-district consent-form carve-out at § 2054.711(c)).
- Submit an annual review to DIR.
- Include AI clauses in vendor contracts.
- Designate an AI Risk Officer (1 TAC § 219.21).
HB 3512 Training and TRAIGA Government Provisions
HB 3512 (effective September 1, 2025) requires state agencies and local governments to annually require DIR-certified AI training for employees and officials who use a computer for at least 25% of their duties, with completion verified and reported to DIR.
TRAIGA (effective January 1, 2026) adds three government-specific rules: § 552.051 requires government agencies (excluding hospital districts and higher education) to disclose AI interaction to consumers — clear and conspicuous, plain language, no dark patterns, hyperlink permitted; § 552.053 prohibits governmental social scoring; and § 552.054 prohibits governmental biometric identification without consent.
How Risk Meridian Helps Texas Public Entities
Risk Meridian runs the full SB 1964 workflow — HSAI classification, risk and impact assessments, standardized notices, vendor-clause tracking, and a DIR Submission Pack for the annual review — plus an HB 3512 training tracker and TRAIGA § 552.051 disclosure generation with §§ 552.053–.054 prohibited-use screening.
Frequently asked questions
Which entities does SB 1964 cover?
Texas governmental entities — including hospital districts, which are notably excluded from TRAIGA's narrower government-agency definition. State agencies, counties, municipalities, and school districts should map their duties under both statutes.
What does TRAIGA § 552.051 require of government agencies?
Disclosure to consumers that they are interacting with AI: clear and conspicuous, in plain language, without dark patterns; a hyperlink is permitted. 'Consumer' means a Texas resident acting in an individual or household context — employment and commercial uses are out of scope.
Who must complete HB 3512 training?
Employees and officials of state agencies and local governments who use a computer for at least 25% of their duties. The training must be DIR-certified, required annually, and completion must be verified and reported to DIR.
What is HSAI classification?
SB 1964 defines Heightened Scrutiny Artificial Intelligence at § 2054.003(6-a) as a binary determination: each AI system either is or is not HSAI, driving assessment and notice obligations accordingly.
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