Relating to certain procedures required for the denial of certain applications for a license to carry a handgun.
LowStandard timeline
Low Cost
Effective:2025-06-20
Enforcing Agencies
Department of Public Safety (DPS) • Medical Advisory Board (MAB)
01
Compliance Analysis
Key implementation requirements and action items for compliance with this legislation
Implementation Timeline
Effective Date: June 20, 2025 (Immediate effect due to supermajority vote).
Compliance Deadline: June 20, 2025. Any original or renewal application submitted on or after this date triggers the new procedural rights.
Agency Rulemaking: The Department of Public Safety (DPS) must update internal adjudication workflows immediately. While formal rulemaking is not explicitly mandated by the bill text, DPS internal policy regarding the handling of "supplemental materials" will likely evolve over Q3 2025.
Immediate Action Plan
Immediate: Audit the expiration dates of all current armed employees. Identify any with known medical disclosures and prioritize their renewals.
Policy Update: Instruct HR to cease immediate rejection of candidates with initial medical flags; establish a protocol to determine if the company will assist in the "cure" process.
Legal Review: Consult with outside counsel regarding liability exposure before agreeing to sign company affidavits attesting to an employee's mental fitness or judgment.
Client Communication: Notify operations managers that onboarding timelines for armed staff may fluctuate due to new statutory due process requirements.
Operational Changes Required
Contracts
Employment Agreements: Update "Condition of Employment" clauses. Ensure language permits unpaid suspension or reassignment if an employee's license renewal is stalled by this new administrative review process.
Client Service Level Agreements (SLAs): Review staffing guarantees. If your contract promises "fully licensed armed guards" within a set timeframe, you must account for potential 30-90 day delays caused by Medical Advisory Board (MAB) reviews. Force Majeure clauses likely do not cover these administrative delays.
Hiring/Training
Recruitment Workflows: HR must adjust "Time-to-Hire" expectations. A medical flag is no longer an immediate disqualifier; it initiates a pause. Implement a "Pending Medical Review" status in your applicant tracking system.
Renewal Monitoring: Initiate renewal reminders for armed staff 90 days earlier than current practice. The new "cure period" creates a risk of license gaps if the review drags past the expiration date.
Reporting & Record-Keeping
Deadline Tracking: If managing licensure for employees, you must track the receipt date of any "Notice of Potential Denial." You have a strict window (minimum 30 days) to submit supplemental materials.
Evidence Retention: If your organization provides affidavits attesting to an employee's "sound judgment" or safe storage practices, retain copies indefinitely in the employee's personnel file for liability defense.
Fees & Costs
Direct Costs: No new state fees are introduced.
Indirect Costs: Increased administrative overhead for HR/Legal teams managing the supplemental submission process. Potential revenue loss if billable staff are sidelined pending license clearance.
Strategic Ambiguities & Considerations
The "Review Void": The law mandates the applicant has *at least* 30 days to respond, but it sets no statutory deadline for the Medical Advisory Board to review the new materials and issue a final report. This could result in indefinite licensure limbo for applicants.
Evidentiary Standards: The term "written materials" is undefined. It is unclear if DPS will prioritize clinical opinions over employer character references. Until DPS clarifies, assume clinical documentation is required to overturn a medical flag.
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Homeland Security, Public Safety & Veterans' Affairs
Committee Report (Unamended)
BACKGROUND AND PURPOSE
Currently, individuals who are denied a license to carry a handgun based on a medical advisory board panel recommendation do not have a formal opportunity to review or respond to the decision before it is finalized. This lack of transparency and review can result in applicants being denied a license without a fair chance to provide additional information regarding their scenario. H.B. 1234 seeks to address this issue by requiring the Department of Public Safety to provide a denied applicant with the reason for the denial and a 30-day period for the applicant to provide additional information for use in supplementing or clarifying the application.
CRIMINAL JUSTICE IMPACT
It is the committee's opinion that this bill does not expressly create a criminal offense, increase the punishment for an existing criminal offense or category of offenses, or change the eligibility of a person for community supervision, parole, or mandatory supervision.
RULEMAKING AUTHORITY
It is the committee's opinion that this bill does not expressly grant any additional rulemaking authority to a state officer, department, agency, or institution.
ANALYSIS
H.B. 1234 amends the Government Code to prohibit the Department of Public Safety (DPS) from denying an application for the issuance of an original or renewal handgun license based on a recommendation for such denial made to DPS by a medical advisory board panel regarding the applicant's capability of exercising sound judgment with respect to the proper use and storage of a handgun, unless DPS first provides the applicant with the following:
·a written notice that specifically states the reason underlying the recommendation for denial; and
·a period of not less than 30 days in which the applicant may provide additional written materials to DPS to supplement or clarify the applicant's application.
H.B. 1234 requires DPS to forward any materials received in the 30-day period to the medical advisory board panel that made the recommendation for denial. The bill requires each panel member, after reviewing the additional written materials, to submit an additional written report to DPS stating the panel member's opinion as to the applicant's ability to exercise sound judgment with respect to the proper use and storage of a handgun. The bill requires DPS to then review the application and determine whether to issue the license or to deny the application.
H.B. 1234 applies only to an application for the issuance of an original or renewal handgun license submitted on or after the bill's effective date. An application submitted before the bill's effective date is governed by the law in effect on the date the application was submitted, and the former law is continued in effect for that purpose.
HB1234 mandates a new administrative review layer for License to Carry (LTC) applicants flagged for medical or psychological issues, creating a mandatory "cure period" of at least 30 days before a final denial can be issued. This legislation directly impacts hiring timelines and renewal continuity for private security firms and entities requiring armed personnel as a condition of employment. Implementation Timeline Effective Date: June 20, 2025 (Immediate effect due to supermajority vote).
Q
Who authored HB1234?
HB1234 was authored by Texas Representative Ryan Guillen during the Regular Session.
Q
When was HB1234 signed into law?
HB1234 was signed into law by Governor Greg Abbott on June 20, 2025.
Q
Which agencies enforce HB1234?
HB1234 is enforced by Department of Public Safety (DPS) and Medical Advisory Board (MAB).
Q
How urgent is compliance with HB1234?
The compliance urgency for HB1234 is rated as "low". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of HB1234?
The cost impact of HB1234 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does HB1234 address?
HB1234 addresses topics including health, health--general, weapons and public safety, department of.
Legislative data provided by LegiScanLast updated: November 25, 2025
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