HB1237

Regular Session

Relating to the renewal by the Texas Commission on Environmental Quality of certain expired occupational licenses and registrations.

ModeratePlan for compliance

Low Cost

Effective:2025-06-20

Enforcing Agencies

Texas Commission on Environmental Quality (TCEQ)

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 passage).
Compliance Deadline: Immediate. You may utilize the extended renewal windows and "Safe Harbor" provisions today to salvage licenses expired less than 180 days.
Agency Rulemaking: TCEQ must amend 30 TAC Chapter 30 to formalize fee amounts. Regulatory Gray Zone: While the law is active, TCEQ’s online portal may still enforce the old 30-day block. Manual submission (certified mail) may be required until IT systems are updated.

Immediate Action Plan

Audit Personnel Files: Immediately identify any licenses expired between 30 and 180 days. These are no longer "dead"; file for renewal immediately to restore their status.
Update Compliance Manuals: Replace the "30-day hard stop" rule with the new 180-day tiered protocol.
Verify Insurance: Obtain written confirmation from carriers regarding coverage for employees working under the §37.006(f) Safe Harbor.
Monitor TCEQ Portal: Instruct administrative staff to use certified mail for renewals if the online system blocks an application that is legally valid under HB1237.

Operational Changes Required

Contracts

Vendor Agreements/MSAs: Standard clauses requiring personnel to hold "valid and active licenses" are now risky. Amend "Representations and Warranties" to include "or individuals authorized to operate under Texas Water Code §37.006(f)."
Insurance Liability: Contact your broker immediately. Confirm that Professional Liability (E&O) and General Liability carriers recognize the statutory "Safe Harbor" (0–90 days pending renewal) as "licensed" for coverage purposes. Do not assume coverage exists for expired-but-working staff.

Hiring/Training

HR Policy Revision: Update termination/suspension protocols.
0–90 Days Expired: Employee continues working (if renewal filed).
91–180 Days Expired: Employee must be "benched" or reassigned to non-licensed duties.
181+ Days Expired: License is void; employee must re-test as a new applicant.
Recruitment: You can now hire/retain individuals with recently expired licenses (up to 6 months) without waiting for them to re-take exams, provided you pay the late fees.

Reporting & Record-Keeping

New Documentation Standard: For any employee working in the 0–90 day grace period, you must maintain proof of submission of the renewal application (e.g., payment receipt or certified mail log) in the compliance file. This document now serves as their "license" during inspections.

Fees & Costs

Late Fee Structure:
0–90 Days: Capped at 1.5x standard renewal fee.
91–180 Days: Capped at 2.0x standard renewal fee.
Payroll Impact: Review employment contracts to determine if these increased penalties can be deducted from employee compensation or if the company must absorb the cost.

Strategic Ambiguities & Considerations

Portal Functionality: The TCEQ licensing portal likely lacks the logic to process a renewal at Day 45 or Day 100. If the portal rejects a renewal, do not accept it as final. The statute overrides the software. Submit via paper/mail immediately to preserve rights.
Fee Specifics: The statute sets a "cap" (not to exceed 1.5x/2x), but TCEQ has not set the specific dollar amount. Operational Assumption: Budget for the maximum cap until rulemaking is finalized.

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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.

Legislative Timeline

This bill's path through the Texas Legislature

TopicsEnvironment Environment--general Utilities Utilities--water & Sewer Fees & Other Nontax Revenue Fees & Other Nontax Revenue--state Occupational Regulation Occupational Regulation--other Trades & Professions Environmental Quality, Texas Commission On

Official Analysis

View HRO Analysis View All Bill Documents

BILL ANALYSIS

H.B. 1237

By: Guillen

Environmental Regulation

Committee Report (Unamended)

BACKGROUND AND PURPOSE

The bill author has informed the committee that current law only allows a 30-day window for the renewal of an expired occupational license issued by the Texas Commission on Environmental Quality and that after this period a person may not renew the license but may obtain a new license by complying with the requirements and procedures for obtaining an original license. The bill author has also informed the committee that this short time frame can lead to unnecessary lapses that impact workers and industries that rely on these licenses. H.B. 1237 seeks to help prevent unnecessary disruptions in employment and industry operations caused by expired licenses by extending the renewal period in order to provide flexibility for professionals who may miss the renewal deadline due to unforeseen circumstances, while maintaining accountability through increased fees for late renewals.

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 rulemaking authority is expressly granted to the Texas Commission on Environmental Quality in SECTION 1 of this bill.

ANALYSIS

H.B. 1237 amends the Water Code to change from 30 days or less to not more than 90 days the period of time during which a person's occupational license or registration issued by the Texas Commission on Environmental Quality (TCEQ) has been expired that triggers the authorization for the person to apply for renewal of the license or registration by paying to the TCEQ a renewal fee in an amount prescribed by TCEQ rule not to exceed 1-1/2 times the normally required renewal fee. The bill authorizes a person whose license or registration has been expired for at least 90 days but not more than one year to apply for renewal of the license or registration by paying to the TCEQ a renewal fee in an amount prescribed by TCEQ rule not to exceed two times the normally required renewal fee. The bill changes from more than 30 days to at least one year the amount of time that a person's license or registration has been expired that triggers the prohibition against the renewal of the license or registration.

EFFECTIVE DATE

September 1, 2025.

House Authors

Rep. Ryan GuillenRepublican · Primary Author

Senate Sponsor

Sen. Judith ZaffiriniDemocrat · Primary Sponsor

Bill Text(with markup)

H.B. No. 1237

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

	AN ACT
	relating to the renewal by the Texas Commission on Environmental
	Quality of certain expired occupational licenses and
	registrations.
	BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF TEXAS:
	SECTION 1. Section 37.006, Water Code, is amended by
	amending Subsections (f) and (g) and adding Subsection (h) to read
	as follows:
	(f) A person whose license or registration has been expired
	for not more than 90 [30] days [~~or less~~] may apply for renewal of the
	license or registration by paying to the commission a renewal fee in
	an amount prescribed by commission rule not to exceed 1-1/2 times
	the normally required renewal fee. Notwithstanding Subsection (e),
	a person who has applied for renewal of the license or registration
	under this subsection may engage in activities that require a
	license or registration after the expiration of the license or
	registration until the license or registration is renewed or
	denied.
	(g) A person whose license or registration has been expired
	for at least 90 days but not more than 180 days may apply for renewal
	of the license or registration by paying to the commission a renewal
	fee in an amount prescribed by commission rule not to exceed two
	times the normally required renewal fee.
	(h) A person whose license or registration has been expired
	for at least 180 days [~~more than 30 days~~] may not renew the license
	or registration. The person may obtain a new license or
	registration by complying with the requirements and procedures,
	including the examination requirements, for obtaining an original
	license or registration.
	SECTION 2. This Act takes effect September 1, 2025.

LEGISLATIVE BUDGET BOARD
Austin, Texas

FISCAL NOTE, 89TH LEGISLATIVE REGULAR SESSION


April 16, 2025

TO:	Honorable Brooks Landgraf, Chair, House Committee on Environmental Regulation

FROM:	Jerry McGinty, Director, Legislative Budget Board

IN RE:	HB1237 by Guillen (Relating to the renewal by the Texas Commission on Environmental Quality of certain expired occupational licenses and registrations.), As Introduced

The fiscal implications of the bill cannot be determined because the number of individuals who would renew their licenses or registrations under the extended renewal periods is unknown at this time.

The bill would make no appropriation but could provide the legal basis for an appropriation of funds to implement the provisions of the bill.

The bill would amend Water Code to expand the Texas Commission on Environmental Quality (TCEQ) requirements and uniform procedures for renewing licenses and registrations.

The bill would allow for certain licenses or registrations issued by TCEQ that have been expired for up to 90 days to be renewed by paying a renewal fee set by TCEQ in an amount not to exceed one and a half times the normally required renewal fee. The bill would allow TCEQ to charge a fee up to two times the normally required fee if a license or registration has been expired for at least 90 days but less than one year. The bill would prohibit the renewal of a license or registration that has been expired for at least one year. The application fees for licenses and renewals governed by the bill would be deposited to the credit of General Revenue-Dedicated Texas Commission on Environmental QualityOccupational Licensing Account No. 468.

According to TCEQ and the Comptroller of Public Accounts, thefiscal implications of the bill cannot be determined because the number of individuals who would renew licenses or registrations under the extended renewal periods is unknown at this time.

Based on information provided by TCEQ, it is assumed that any costs associated with the bill could be absorbed using existing resources.

Local Government Impact

The fiscal implications of the bill cannot be determined at this time.

Source Agencies:

304 Comptroller of Public Accounts, 582 Commission on Environmental Quality

LBB Staff:

JMc, FV, MW, AJL

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Frequently Asked Questions

Common questions about HB1237

What does Texas HB1237 do?

Effective immediately, HB1237 fundamentally restructures TCEQ occupational license renewals, extending the expiration grace period from 30 days to 180 days. The critical operational change is the creation of a "Safe Harbor" (0–90 days post-expiration) where employees may legally continue working if a renewal application is pending, preventing unnecessary work stoppages. Implementation Timeline Effective Date: June 20, 2025 (Immediate effect due to supermajority passage).

Who authored HB1237?

HB1237 was authored by Texas Representative Ryan Guillen during the Regular Session.

When was HB1237 signed into law?

HB1237 was signed into law by Governor Greg Abbott on June 20, 2025.

Which agencies enforce HB1237?

HB1237 is enforced by Texas Commission on Environmental Quality (TCEQ).

How urgent is compliance with HB1237?

The compliance urgency for HB1237 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.

What is the cost impact of HB1237?

The cost impact of HB1237 is estimated as "low". This may vary based on industry and implementation requirements.

What topics does HB1237 address?

HB1237 addresses topics including environment, environment--general, utilities, utilities--water & sewer and fees & other nontax revenue.

Legislative data provided by LegiScanLast updated: November 25, 2025

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