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SB2443

Regular Session

Relating to electronic delivery of documents sent or received by the Texas Department of Licensing and Regulation.

Moderate
Low Cost
Effective:2025-09-01
SB2443
Moderate
Relating to electronic delivery of documents sent or received by the Texas Department of Licensing and Regulation.
Moderate Compliance Urgency
Requires near-term attention
Cost Impact
Low
Effective
2025-09-01
Enforcing Agencies
TCLRTDLR
Primary Author: Sen. Judith Zaffirini
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: Contingent upon TCLR rulemaking; anticipate mandatory email verification and enrollment during the first license renewal cycle occurring after January 1, 2026.
  • Agency Rulemaking: The Texas Commission of Licensing and Regulation (TCLR) is required to adopt rules to operationalize this statute. A "regulatory gray zone" will exist between the effective date and final rule adoption regarding how "delivery failure" is handled.

Immediate Action Plan

  • 1. Audit Current Records: Identify every email address currently on file with TDLR for all entity and individual licenses under your management.
  • 2. Establish Centralized Inbox: Create a generic, monitored email address (e.g., `compliance@yourdomain.com`) to replace personal email addresses on all filings.
  • 3. Update IT Whitelists: Configure email security gateways to ensure 100% deliverability from `tdlr.texas.gov`.
  • 4. Monitor Rulemaking: Assign a team member to track TCLR agenda items regarding "electronic delivery rules" to submit comments regarding bounce-back protections.

Operational Changes Required

Contracts

  • Employment Agreements: Review contracts for employees who hold licenses required for your business operation (e.g., Master Electricians, HVAC technicians). You must mandate the use of a company-controlled email address for their TDLR contact information to ensure the business retains access to regulatory notices if the employee terminates.
  • Registered Agents: Review Third-Party Registered Agent agreements. Since TDLR may bypass the agent and email the licensee directly, clarify who holds the primary responsibility for monitoring the regulatory inbox.

Hiring/Training

  • IT Protocols: IT departments must whitelist the `tdlr.texas.gov` domain immediately. Spam filters catching a Notice of Alleged Violation (NOV) constitute a valid service of process under this law.
  • Staff Training: Administrative staff monitoring the designated inbox must be trained to recognize TDLR correspondence as formal legal service, requiring immediate escalation to Legal/Compliance rather than standard administrative handling.

Reporting & Record-Keeping

  • Dedicated Inbox: Abandon the use of individual employee email addresses (e.g., `jane.doe@company.com`) for licensing. Establish a permanent, multi-user distribution list (e.g., `licensing@company.com`) to serve as the official address of record.
  • Digital Chain of Custody: Implement archiving protocols for this inbox. In the event of a contested default judgment, server logs proving non-receipt will be your primary defense.

Fees & Costs

  • No Statutory Fees: There are no new fees associated with this filing.
  • Operational Costs: Minimal costs associated with IT configuration and email archiving storage.

Strategic Ambiguities & Considerations

  • Bounce-Back Protocols: The statute is silent on TDLR's obligation if an email returns a "delivery failure" notification. Rulemaking must determine if this triggers a fallback to certified mail or constitutes valid service regardless of technical failure.
  • Definition of "Delivery": It is currently undefined whether "electronic delivery" implies sending the full legal document as an attachment (a security risk) or a notification to log into a secure portal.
  • Service on Counsel: The law does not specify how electronic service interacts with a licensee’s retained counsel. We must monitor rules to ensure service is directed to the attorney of record once representation is established.

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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
Mar 13, 2025
Passed Senate
Apr 24, 2025
Passed House
May 23, 2025
Signed
Jun 20, 2025
TopicsElectronic Information SystemsOccupational RegulationOccupational Regulation--health OccupationsOccupational Regulation--other Trades & ProfessionsEmail & Electronic CommunicationsLicensing & Regulation, Texas Department ofLicensing & Regulation, Texas Commission of
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Senate Authors

Sen. Judith ZaffiriniDemocrat · Primary Author

House Sponsor

Rep. Dade PhelanRepublican · 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. Judith Zaffirini

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Related by Topic

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Quick Reference

Frequently Asked Questions

Common questions about SB2443

Q

What does Texas SB2443 do?

SB2443 mandates a fundamental shift in how the Texas Department of Licensing and Regulation (TDLR) executes service of process, moving from certified mail to mandatory electronic delivery for all licensees. This legislation creates immediate procedural risk: failure to monitor the designated email address can result in a Default Order—revoking licenses and assessing penalties—without the physical "green card" receipt previously required to prove notice. Implementation Timeline Effective Date: September 1, 2025 Compliance Deadline: Contingent upon TCLR rulemaking; anticipate mandatory email verification and enrollment during the first license renewal cycle occurring after January 1, 2026.

Q

Who authored SB2443?

SB2443 was authored by Texas Senator Judith Zaffirini during the Regular Session.

Q

When was SB2443 signed into law?

SB2443 was signed into law by Governor Greg Abbott on June 20, 2025.

Q

Which agencies enforce SB2443?

SB2443 is enforced by Texas Commission of Licensing and Regulation (TCLR) and Texas Department of Licensing and Regulation (TDLR).

Q

How urgent is compliance with SB2443?

The compliance urgency for SB2443 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.

Q

What is the cost impact of SB2443?

The cost impact of SB2443 is estimated as "low". This may vary based on industry and implementation requirements.

Q

What topics does SB2443 address?

SB2443 addresses topics including electronic information systems, occupational regulation, occupational regulation--health occupations, occupational regulation--other trades & professions and email & electronic communications.

Legislative data provided by LegiScanLast updated: November 25, 2025

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