JD Key Consulting Logo
Signed Into Law
Signed June 20, 2025Effective 2025-09-01
HB1991

Regular Session

Relating to information regarding certain charges for services provided by municipally owned utility systems.

Government Affairs & Regulatory Compliance Analysis

HB1991: Government Affairs Overview

HB1991 mandates strict digital transparency for municipally owned utility systems, requiring the online publication of all terms, conditions, and charges related to operations, maintenance, and improvements. While the statutory duty falls on municipalities, this law creates immediate contractual obligations for private utility operators and establishes a critical audit mechanism for commercial developers and high-volume utility consumers to contest undocumented fees.

Rep. Ryan Guillen·House Bill·Regular Session

Moderate
Low Cost
Effective:2025-09-01

Need Help Navigating This Legislation?

JD Key Consulting provides strategic guidance on Texas regulatory compliance and legislative impact for your business.

HB1991
Relating to information regarding certain charges for services provided by municipally owned utility systems.
Moderate Urgency
Unanimous Passage
House Vote120 - 0
YEA
100% in favor120 voting
Senate Vote31 - 0
YEA
100% in favor31 voting
Cost Impact
Low
Effective
2025-09-01
Primary Author: Rep. Ryan Guillen
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: September 1, 2025 (All current charges must be posted). For future changes, updates must be posted no later than 30 days after the municipality adopts the change.
  • Agency Rulemaking: None. This is a self-executing statutory requirement for local governments; however, interpretation of "terms and conditions" will likely be defined through initial litigation or Attorney General opinions.

Immediate Action Plan

  • Audit Invoices: Direct Finance to identify all municipal utility accounts and flag "non-consumption" charges (maintenance, improvement fees).
  • Snapshot Baseline: On September 2, 2025, archive the utility pages of every municipality where you operate or own major assets.
  • Review MSAs: If you operate a utility for a city, issue a formal notice to the City Manager regarding their new obligation to publish data you provide.
  • Dispute Protocol: Create a standard objection letter for AP departments to use when an invoiced charge does not match the website.

Operational Changes Required

Contracts

  • Utility Operators: Review Master Services Agreements (MSAs) with municipalities immediately. If you manage the data, ensure the contract explicitly assigns the legal liability for *publishing* that data to the municipality. Insert indemnification clauses protecting your firm from citizen lawsuits if the city fails to update its website within the 30-day window.
  • Developers: When negotiating Chapter 380 or connection agreements, draft clauses that tie utility rates specifically to "charges published in accordance with Texas Government Code Section 1502.057." This prevents the enforcement of "hidden" council-approved fees that were not publicly disclosed.

Hiring/Training

  • Accounts Payable (Commercial Consumers): Train AP staff to verify municipal utility invoices against the municipality's website. If a "capital improvement" or "replacement" charge appears on an invoice but is not listed on the website, it is contestable.
  • IT/Web Teams (Utility Operators): Establish a rigid workflow to push rate data to municipal webmasters immediately upon adoption to ensure the 30-day statutory window is met.

Reporting & Record-Keeping

  • Digital Archiving: Businesses engaged in disputes with municipalities must implement a "snapshot" protocol. Capture and timestamp the municipality’s utility webpage monthly. In a billing dispute, the burden will be on you to prove what terms were displayed on the specific date of service.
  • Synchronization: If the utility system maintains a website separate from the municipality, the law requires posting on *both*. Operators must ensure these data sets are identical to avoid ambiguity claims.

Fees & Costs

  • No Direct Fee Increases: The law does not mandate new fees.
  • Cost Containment: This is a cost-saving tool for businesses. It provides a statutory basis to reject utility charges that do not strictly conform to the published terms.

Strategic Ambiguities & Considerations

  • "Terms and Conditions": The law requires publication of "terms and conditions," not just rates. Municipalities may attempt to publish only the rate table. Businesses should take the position that *any* penalty, surcharge, or peak-demand rule not published on the website is unenforceable.
  • "Improvement Charges": The definition of charges for "improvement" is broad. Watch for municipalities attempting to categorize Impact Fees or Capital Recovery Fees outside of this requirement to avoid publication.
  • Website Discrepancies: The law requires posting on both the utility's and the city's websites. If these conflict, businesses should argue for the application of the rate/term most favorable to the consumer (contra proferentem).

Need Compliance Guidance on This Legislation?

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 Consultation

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
Jan 22, 2025
Passed House
May 16, 2025
Passed Senate
May 25, 2025
Signed
Jun 20, 2025
Effective
Sep 1, 2025
TopicsCity GovernmentCity Government--utilitiesUtilitiesUtilities--generalSecretary of StatePublic Notice
03

House Authors

Rep. Ryan GuillenRepublican · Primary Author
Coauthors (1)

Senate Sponsor

Sen. Roland GutierrezDemocrat · Primary Sponsor

Bill Text(with markup)

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

Related Legislation

Explore more bills from this author and on related topics

More from Rep. Ryan Guillen

View all bills by Rep. Ryan Guillen

Related by Topic

View more City Government legislation
Quick Reference

Frequently Asked Questions

Common questions about HB1991

Q

What does Texas HB1991 do?

HB1991 mandates strict digital transparency for municipally owned utility systems, requiring the online publication of all terms, conditions, and charges related to operations, maintenance, and improvements. While the statutory duty falls on municipalities, this law creates immediate contractual obligations for private utility operators and establishes a critical audit mechanism for commercial developers and high-volume utility consumers to contest undocumented fees.

Q

Who authored HB1991?

HB1991 was authored by Texas Representative Ryan Guillen during the Regular Session.

Q

When was HB1991 signed into law?

HB1991 was signed into law by Governor Greg Abbott on June 20, 2025.

Q

How significant are the changes in HB1991?

The regulatory priority for HB1991 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of HB1991?

The cost impact of HB1991 is estimated as "low". This may vary based on industry and implementation requirements.

Q

What topics does HB1991 address?

HB1991 addresses topics including city government, city government--utilities, utilities, utilities--general and secretary of state.

Q

What are the key dates for HB1991?

Key dates for HB1991: Effective date is 2025-09-01. Consult with legal counsel regarding applicability.

Q

Which Texas businesses are affected by HB1991?

HB1991 primarily affects utility companies and energy providers. These businesses should review the legislation with their legal and compliance teams to understand potential impacts.

Need Strategic Guidance on This Legislation?

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.

Legislative data provided by LegiScanLast updated: January 11, 2026