Relating to the security of certain personal identifying information submitted to or retained by a state agency.
ModeratePlan for compliance
Low Cost
Effective:2025-06-20
Enforcing Agencies
Texas Department of Licensing and Regulation (TDLR) • Texas Medical Board • Texas Board of Nursing • Texas Real Estate Commission • All state agencies issuing occupational licenses (excluding the Comptroller)
01
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 vote).
Compliance Deadline:Immediate. State agencies must cease dissemination of non-consented data today. Third-party data consumers must adjust ingestion pipelines immediately, as new data pulls will be redacted.
Agency Rulemaking: Agencies (TDLR, TMB, TREC) must implement mechanisms to capture "written consent." Expect a 30-90 day regulatory gray zone where agencies will likely default to total redaction of contact info while they update IT portals to handle opt-in preferences.
Immediate Action Plan
1.Audit Data Feeds: Check your automated data ingestion from state boards (Medical Board, Real Estate Commission, etc.) today. If fields are coming back null, stop the sync to prevent overwriting existing data with blanks.
2.Notify Licensees: Send an internal memo to your licensed staff instructing them to log into their state portals and ensure their "Business Address" and "Business Email" are populated and distinct from their home/personal data.
3.Update Verification SOPs: Instruct compliance teams that a lack of address match on a state website is no longer a red flag for fraud; it is now the legal default.
4.Demand Vendor Warranties: Require data brokers to certify in writing that their Texas data is sourced compliantly post-June 20, 2025.
Operational Changes Required
Contracts
Data Vendor Agreements: Immediately review contracts with lead-generation or background check vendors. If their deliverables rely on "publicly available state records" for contact info, they can no longer fulfill the contract. Invoke force majeure or renegotiate terms if they cannot provide alternative, consensually sourced data.
Employment Agreements: For businesses that employ licensed professionals (e.g., hospitals, brokerages, HVAC firms), amend employment contracts to require employees to sign the state's "Consent to Release" form. This ensures the employer can verify licensure status and receive agency notices regarding the employee.
Hiring/Training
Credentialing Teams: Retrain staff to stop using home addresses or phone numbers as primary identifiers for license verification. Verification must now rely strictly on License Numbers, NPI numbers, or business addresses.
Recruitment/Marketing: Marketing teams must cease "scraping" state agency websites for leads. Campaigns based on these lists will fail as email and phone fields will now be blank or redacted.
Reporting & Record-Keeping
Consent Management: If you manage a fleet of licensed professionals, you must track which employees have submitted their consent forms to the state.
Database Hygiene: Update your internal databases to distinguish between "Business" and "Personal" contact information. The state will only release data explicitly designated as "Business."
Fees & Costs
Direct Costs: No new state fees.
Indirect Costs: Expect increased costs for recruitment and lead generation, as free/cheap public data is replaced by more expensive, privately sourced opt-in data.
Strategic Ambiguities & Considerations
Business vs. Personal Distinction: The law protects "personal" emails and "home" addresses but does not define how an agency distinguishes these from "business" details if a licensee uses a personal Gmail account for work. Expect agencies to over-correct and redact ALL contact information initially to avoid liability.
Mechanism of Consent: The law requires "written consent" but does not specify if a digital checkbox on a renewal form suffices. Until agencies clarify this via rulemaking, the default status for all licensees is "Confidential."
Public Information Act (PIA) Conflict: While the PIA presumes openness, this statute creates a specific exception. Do not waste legal budget filing PIA requests for this data; the Attorney General will almost certainly rule that HB5129 overrides general PIA disclosure requirements.
Need Help Understanding Implementation?
Our government affairs experts can walk you through this bill's specific impact on your operations.
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.
The bill author has informed the committee that there are currently no statutory provisions protecting Texans who hold an occupational or professional license with a state agency from the dissemination of their personal information through a public information request directed to the state agency. C.S.H.B. 5129 seeks to address this issue by ensuring that certain personal information held by state agencies is treated as confidential, preventing sensitive information from being unnecessarily disclosed to the public.
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 this bill does not expressly grant any additional rulemaking authority to a state officer, department, agency, or institution.
ANALYSIS
C.S.H.B. 5129 amends the Government Code to prohibit a state agency from doing the following without written consent:
·disseminating to any person the personal identifying information of a person who submits information to the state agency for the purpose of obtaining an occupational license; or
·retaining such information in the state agency's records in a form that is not entirely redacted.
The bill authorizes a state agency to disseminate such information with respect to a person without the person's written consent if the dissemination is required or permitted by a federal statute or by a state statute other than state public information law, or if the dissemination is made by or to a law enforcement agency for a law enforcement purpose. The bill requires a state agency to retain in the state agency's records the written consent of a person obtained as required under the bill's provisions.
C.S.H.B. 5129 defines "personal identifying information" for purposes of the bill's provisions and statute relating to restrictions on state agency use of certain individual-identifying information by reference to Business & Commerce Code provisions relating to business records. The bill includes in the term a person's home address, home telephone number, personal cell phone number, personal e-mail address, driver's license number, emergency contact information, and information that reveals whether a person has family members.
C.S.H.B. 5129 applies only to information disseminated or retained by a state agency on or after the bill's effective date.
EFFECTIVE DATE
On passage, or, if the bill does not receive the necessary vote, September 1, 2025.
COMPARISON OF INTRODUCED AND SUBSTITUTE
While C.S.H.B. 5129 may differ from the introduced in minor or nonsubstantive ways, the following summarizes the substantial differences between the introduced and committee substitute versions of the bill.
Whereas the introduced version took effect September 1, 2025, the substitute takes effect on passage, or, if it does not receive the necessary vote, September 1, 2025.
Honorable Giovanni Capriglione, Chair, House Committee on Delivery of Government Efficiency
FROM:
Jerry McGinty, Director, Legislative Budget Board
IN RE:
HB5129 by Noble (Relating to the security of certain personal identifying information submitted to or retained by a state agency.), As Introduced
No significant fiscal implication to the State is anticipated.
It is assumed that any costs associated with the bill could be absorbed using existing resources.
Local Government Impact
No significant fiscal implication to units of local government is anticipated.
Source Agencies:
304 Comptroller of Public Accounts, 320 Texas Workforce Commission, 352 Bond Review Board, 452 Department of Licensing and Regulation, 503 Texas Medical Board, 529 Health and Human Services Commission, 582 Commission on Environmental Quality, 601 Department of Transportation, 710 Texas A&M University System Administrative and General Offices, 720 The University of Texas System Administration
LBB Staff:
JMc, RStu, THO, KTw
Related Legislation
Explore more bills from this author and on related topics
HB5129 immediately prohibits Texas state agencies from releasing the home addresses, personal email addresses, and personal cellular numbers of occupational license holders without the licensee's explicit written consent. This legislation effectively restricts public access to contact data for millions of professionals—including doctors, realtors, and tradespeople—forcing an immediate pivot for businesses relying on state databases for recruitment, marketing, or credentialing. Implementation Timeline Effective Date: June 20, 2025 (Immediate effect due to supermajority vote).
Q
Who authored HB5129?
HB5129 was authored by Texas Representative Candy Noble during the Regular Session.
Q
When was HB5129 signed into law?
HB5129 was signed into law by Governor Greg Abbott on June 20, 2025.
Q
Which agencies enforce HB5129?
HB5129 is enforced by Texas Department of Licensing and Regulation (TDLR), Texas Medical Board, Texas Board of Nursing, Texas Real Estate Commission and All state agencies issuing occupational licenses (excluding the Comptroller).
Q
How urgent is compliance with HB5129?
The compliance urgency for HB5129 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of HB5129?
The cost impact of HB5129 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does HB5129 address?
HB5129 addresses topics including open records, protection of personal information, state agencies, boards & commissions, right to privacy act and records management.
Legislative data provided by LegiScanLast updated: November 25, 2025
Need Strategic Guidance on This Bill?
Need help with Government Relations, Lobbying, or compliance? JD Key Consulting has the expertise you're looking for.
