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SB1346

Regular Session

Relating to prohibited sales to persons attempting to purchase all or substantially all possible winning tickets in a lottery drawing.

Critical
High Cost
Effective:2025-09-01
Enforcing Agencies

Texas Lottery Commission

SB1346
Critical
Relating to prohibited sales to persons attempting to purchase all or substantially all possible winning tickets in a lottery drawing.
Critical Compliance Urgency
Requires immediate attention
Cost Impact
High
Effective
2025-09-01
Enforcing Agencies
Texas Lottery Commission
Primary Author: Sen. Bryan Hughes
89th Texas Legislature
jdkey.com
01

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

  • Effective Date: September 1, 2025
  • Compliance Deadline: August 15, 2025 (Training and POS updates must be active prior to the effective date).
  • Agency Rulemaking: The TLC must define "substantially all" and "attempting" prior to enforcement. Expect proposed rules in Q2/Q3 2025. Until these terms are defined, the regulatory gray zone creates high liability risk.

Immediate Action Plan

  • 1. Update POS Systems: Contact your lottery terminal vendor immediately to request hard-stop configurations for anomalous transaction volumes.
  • 2. Revise HR Policies: Issue a memo to all staff stating that facilitating bulk buyouts is grounds for immediate termination.
  • 3. Audit Courier Relationships: Identify any third-party buyers operating in your stores and demand written assurance of compliance with SB1346.
  • 4. Establish "Circuit Breakers": Set internal alerts that notify corporate compliance if a single store's lottery sales spike by more than 200% in a 24-hour period.

Operational Changes Required

Contracts

  • Vendor/Courier Agreements: Review Master Services Agreements (MSAs) with third-party lottery couriers. Insert indemnification clauses holding them liable for lost revenue if their purchasing volume triggers a license revocation.
  • Employment Agreements: Update employee handbooks to define "facilitating bulk lottery purchases" as gross misconduct. This is essential for defending against unemployment claims and mitigating vicarious liability.

Hiring/Training

  • Staff Training: Front-line staff must be trained to identify "syndicate" buying patterns (e.g., coordinated groups buying sequential blocks).
  • Managerial Oversight: Shift authority for high-volume transactions to store managers. Clerks should not have the discretion to process transactions exceeding a specific dollar threshold without a manager's key/code.

Reporting & Record-Keeping

  • Refusal Logs: Implement a mandatory log for "Refused Bulk Sales." Documentation of refused sales is your primary affirmative defense against a claim that you "knowingly allowed" the practice.
  • Surveillance Retention: Align video retention policies with lottery draw cycles to ensure evidence exists to disprove collusion allegations.

Fees & Costs

  • Potential Revenue Loss: The penalty is license revocation, not a fine. The cost impact is the total forfeiture of lottery commissions for a minimum of one year.
  • Software Costs: Budget for Point of Sale (POS) software updates to implement "velocity limits" (hard stops on volume per terminal).

Strategic Ambiguities & Considerations

The statute uses the phrase "attempting to purchase all or substantially all possible winning tickets" but fails to define a percentage or monetary threshold.

  • The "Substantially All" Threshold: Is it 80% of combinations? 95%? Without a specific number, compliance is subjective.
  • The "Knowingly" Standard: It is unclear if liability attaches only when an owner has actual knowledge, or if knowledge is imputed because a manager "should have known" based on sales data.
  • Watch for Rulemaking: The Association will monitor TLC rulemaking for quantitative definitions of these terms.

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Information presented is for general knowledge only and is provided without warranty, express or implied. Consult qualified government affairs professionals and legal counsel before making compliance decisions.

02

Legislative Timeline

This bill's path through the Texas Legislature

Filed
Feb 18, 2025
Passed Senate
Apr 10, 2025
Passed House
May 27, 2025
Signed
Jun 20, 2025
TopicsAmusements, Games, SportsOccupational RegulationOccupational Regulation--other Trades & ProfessionsLottery Commission, TexasLotteries
03

Senate Authors

Sen. Bryan HughesRepublican · Primary Author
Coauthors (1)

House Sponsor

Rep. Jared PattersonRepublican · Primary Sponsor

Bill Text(with markup)

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

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More from Sen. Bryan Hughes

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Quick Reference

Frequently Asked Questions

Common questions about SB1346

Q

What does Texas SB1346 do?

SB1346 introduces a mandatory "death penalty" for Lottery Sales Agents, requiring the Texas Lottery Commission (TLC) to revoke all licenses held by an operator if a single location knowingly facilitates a bulk purchasing scheme. This legislation creates enterprise-wide liability for multi-location retailers (convenience chains, grocery stores), where the actions of one clerk can trigger a total loss of lottery revenue across the entire company. Implementation Timeline Effective Date: September 1, 2025 Compliance Deadline: August 15, 2025 (Training and POS updates must be active prior to the effective date).

Q

Who authored SB1346?

SB1346 was authored by Texas Senator Bryan Hughes during the Regular Session.

Q

When was SB1346 signed into law?

SB1346 was signed into law by Governor Greg Abbott on June 20, 2025.

Q

Which agencies enforce SB1346?

SB1346 is enforced by Texas Lottery Commission.

Q

How urgent is compliance with SB1346?

The compliance urgency for SB1346 is rated as "critical". Businesses and organizations should review the requirements and timeline to ensure timely compliance.

Q

What is the cost impact of SB1346?

The cost impact of SB1346 is estimated as "high". This may vary based on industry and implementation requirements.

Q

What topics does SB1346 address?

SB1346 addresses topics including amusements, games, sports, occupational regulation, occupational regulation--other trades & professions, lottery commission, texas and lotteries.

Legislative data provided by LegiScanLast updated: November 25, 2025

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