Regular Session
Government Affairs & Regulatory Compliance Analysis
HB3848 fundamentally alters the compliance workflow for elevator and escalator inspections by empowering the Texas Department of Licensing and Regulation (TDLR) to mandate electronic filing. Effective September 1, 2025, the "mailbox rule" is eliminated for these submissions; legal compliance will be determined solely by the electronic system’s timestamp, affecting all commercial property owners and facility managers.
Rep. Ana Hernandez·House Bill·Regular Session
This legislation has regulatory implications for the following Texas businesses and organizations:
Notable regulatory updates (effective 2025-09-01). Consider how these changes may affect your operations.
Affected business types:
lowMinimal cost impact anticipated.
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JD Key Consulting provides strategic guidance on Texas regulatory compliance and legislative impact for your business.
Key implementation requirements and action items for compliance with this legislation
You must amend Master Service Agreements (MSAs) with elevator inspection vendors immediately. Explicitly define whether the Owner or the Inspector is the designated "filer." Include indemnification clauses holding the vendor liable for penalties resulting from their failure to electronically submit reports or fees by the deadline.
Train accounts payable and facilities staff to transition from physical check issuance to electronic payment methods (ACH or corporate credit card). Staff must understand that mailing a physical report or check will no longer satisfy the "timely filing" requirement.
Shift internal audit protocols from retaining certified mail receipts to archiving digital confirmation numbers. Do not rely solely on the TDLR portal for history; download and save a PDF copy of the electronic submission receipt and the filed report immediately upon submission to establish an independent audit trail.
While statutory filing fees remain unchanged, budget for potential 2-3% third-party payment processing or "convenience" fees associated with the electronic portal.
The statute does not currently provide a "safe harbor" provision for late filings caused by TDLR system outages or portal crashes. Additionally, the bill allows the Commission to *require* electronic filing, implying that paper submissions sent via mail after rule adoption could be rejected outright, resulting in immediate non-compliance. We will advocate for outage protections during the rulemaking phase.
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 HB3848
HB3848 fundamentally alters the compliance workflow for elevator and escalator inspections by empowering the Texas Department of Licensing and Regulation (TDLR) to mandate electronic filing. Effective September 1, 2025, the "mailbox rule" is eliminated for these submissions; legal compliance will be determined solely by the electronic system’s timestamp, affecting all commercial property owners and facility managers.
HB3848 was authored by Texas Representative Ana Hernandez during the Regular Session.
HB3848 was signed into law by Governor Greg Abbott on June 20, 2025.
HB3848 is enforced by Texas Department of Licensing and Regulation (TDLR).
The regulatory priority for HB3848 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of HB3848 is estimated as "low". This may vary based on industry and implementation requirements.
HB3848 addresses topics including electronic information systems, occupational regulation, occupational regulation--other trades & professions, email & electronic communications and elevators.
Key dates for HB3848: Effective date is 2025-09-01. Rulemaking: Must adopt rules defining the prescribed manner and specific electronic system for submitting inspection reports and fees. (Prior to 2025-09-01 (Operational necessity)). 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.
