Regular Session
Government Affairs & Regulatory Compliance Analysis
The Texas Legislature has mandated that all massage student permits issued by the Texas Department of Licensing and Regulation (TDLR) must now include a photograph of the student's face. This requirement strictly affects licensed massage schools, necessitating immediate updates to enrollment intake procedures and physical permit displays to avoid administrative penalties for improper documentation.
Rep. Ana Hernandez·House Bill·Regular Session
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Key implementation requirements and action items for compliance with this legislation
Update Student Enrollment Agreements immediately. You must add a specific clause granting the school permission to capture, store, and publicly display the student's photograph for regulatory compliance purposes. Do not rely on existing marketing media releases, as they may not cover mandatory regulatory display.
Admissions staff must be trained on new photo-capture protocols during the intake process. Administrative personnel responsible for TDLR filings must be retrained on the updated portal submission process, which will likely require digital image uploads.
Student permanent files must now include a secure digital headshot. The physical display of student permits within the school facility—mandatory under existing law—must be updated to ensure the new permits with photos are clearly visible to inspectors and the public.
There are no new state licensing fees associated with this bill. However, schools must budget for increased internal operational costs regarding color printing, ink/toner, and digital camera hardware to produce legible photo permits.
Retroactivity (The "Grandfather" Issue): The statute does not explicitly exempt students enrolled *prior* to September 1, 2025, whose permits are already active. TDLR rulemaking may require you to reissue permits with photos for your entire existing student body.
Photo Specifications: The law requires a "photograph of the student's face" but lacks technical standards. We anticipate TDLR will align this with driver’s license standards (plain background, no hats/glasses).
Issuance Mechanism: It is unclear if TDLR will mail physical photo cards or if schools will be required to print photo-embedded PDFs generated by the TDLR system.
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.
Schedule a ConsultationInformation 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.
This bill's path through the Texas Legislature
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Common questions about HB1562
The Texas Legislature has mandated that all massage student permits issued by the Texas Department of Licensing and Regulation (TDLR) must now include a photograph of the student's face. This requirement strictly affects licensed massage schools, necessitating immediate updates to enrollment intake procedures and physical permit displays to avoid administrative penalties for improper documentation.
HB1562 was authored by Texas Representative Ana Hernandez during the Regular Session.
HB1562 was signed into law by Governor Greg Abbott on June 20, 2025.
HB1562 is enforced by Texas Commission of Licensing and Regulation and Texas Department of Licensing and Regulation.
The regulatory priority for HB1562 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of HB1562 is estimated as "low". This may vary based on industry and implementation requirements.
HB1562 addresses topics including occupational regulation, occupational regulation--other trades & professions, massage therapy & massage therapists, licensing & regulation, texas commission of and licensing & regulation, texas department of.
Key dates for HB1562: Effective date is 2025-09-01. Rulemaking: Adopt rules necessary to implement the photograph requirement for student permits. (As soon as practicable). Consult with legal counsel regarding applicability.
HB1562 establishes the following penalties: administrative penalty of Subject to existing TDLR administrative sanctions for Failure to ensure student permits contain a photograph or failure to display permits properly.. Consult with legal counsel for specific applicability to your situation.
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.
