Regular Session
Government Affairs & Regulatory Compliance Analysis
HB128 mandates the immediate termination of all sister-city agreements between Texas governmental entities and designated foreign adversaries (China, Iran, North Korea, Russia). While directed at municipalities, this law effectively voids related private-sector contracts for cultural exchange, trade consulting, and delegation logistics by October 1, 2025.
Rep. Angelia Orr·House Bill·Regular Session
Political Subdivisions (Cities, Counties, School Districts) • State Agencies (Self-Compliance)
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Key implementation requirements and action items for compliance with this legislation
Master Services Agreements (MSAs) with municipalities involving international relations, trade missions, or cultural exchanges must be amended immediately to exclude prohibited nations. Expect "Impossibility of Performance" termination notices for any active contracts supporting delegations to these regions. You must proactively carve out these deliverables to preserve the remainder of your municipal contracts.
Compliance officers must update vendor and partner screening protocols. Cross-reference the Chapter 2275 Foreign Adversary list against all potential municipal partnership opportunities. Staff managing international logistics must be retrained to flag and block bookings involving designated adversaries when public funds are involved.
Governmental entities must execute and archive formal Board Resolutions authorizing withdrawal. Private partners acting as intermediaries (e.g., Economic Development Corporations) must retain certified copies of these resolutions and proof of delivery of the withdrawal notice to the foreign entity to protect against *ultra vires* (unauthorized acts) liability.
There are no statutory filing fees. However, businesses should anticipate unrecoverable costs for cancelled events or travel bookings. Municipalities will likely claim statutory compulsion to avoid paying cancellation penalties or damages for breach of contract.
The statute defines a "sister-city agreement" partially by recognition from the "Sister Cities International" non-profit. It is legally ambiguous whether independent "Friendship Pacts" or MOUs outside this organization's purview are strictly covered. Guidance: Do not rely on this technicality. Treat *all* bilateral agreements with foreign adversaries as prohibited to avoid reputational risk and contract voidance. Additionally, the list of "Foreign Adversaries" is dynamic; the ban automatically extends to any future additions to the Chapter 2275 list.
JD Key Consulting specializes in Texas regulatory compliance strategy. Work directly with James Dickey—former Chairman of the Republican Party of Texas—to understand this bill's impact on your operations and develop an actionable compliance plan.
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This bill's path through the Texas Legislature
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Common questions about HB128
HB128 mandates the immediate termination of all sister-city agreements between Texas governmental entities and designated foreign adversaries (China, Iran, North Korea, Russia). While directed at municipalities, this law effectively voids related private-sector contracts for cultural exchange, trade consulting, and delegation logistics by October 1, 2025.
HB128 was authored by Texas Representative Angelia Orr during the Regular Session.
HB128 was signed into law by Governor Greg Abbott on June 20, 2025.
HB128 is enforced by Political Subdivisions (Cities, Counties, School Districts) and State Agencies (Self-Compliance).
The regulatory priority for HB128 is rated as "critical". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of HB128 is estimated as "low". This may vary based on industry and implementation requirements.
HB128 addresses topics including city government, city government--general, intergovernmental relations, political subdivisions and state agencies, boards & commissions.
Key dates for HB128: Effective date is 2025-06-20. Consult with legal counsel regarding applicability.
JD Key Consulting is an Austin, Texas-based government affairs firm led by James Dickey, former Chairman of the Republican Party of Texas. We specialize in Texas regulatory compliance and legislative strategy for data centers, energy, banking, and manufacturing.
