JD Key Consulting Logo
Signed Into Law
Signed June 20, 2025Effective 2026-01-01
HB851

Regular Session

Relating to the determination and reporting of the number of residence homesteads of certain property owners for which the owner is receiving certain ad valorem tax benefits.

Government Affairs & Regulatory Compliance Analysis

HB851: Government Affairs Overview

HB851 mandates that County Appraisal Districts (CADs) aggregate and report specific homestead data—specifically regarding tax ceilings, deferrals, and abatements—to the State Comptroller annually. While the statutory burden lies with Chief Appraisers, the operational burden falls squarely on government software vendors and IT directors, who must reconfigure CAMA (Computer-Assisted Mass Appraisal) systems to generate these reports without transmitting Personal Identifying Information (PII).

Rep. Mike Schofield·House Bill·Regular Session

Low
Low Cost
Effective:2026-01-01
Business Impact

Who HB851 Affects

This legislation has regulatory implications for the following Texas businesses and organizations:

Regulatory Priority: low

Standard regulatory changes (effective 2026-01-01). Review during normal business planning.

🏢

Real Estate

Affected business types:

  • Property developers
  • Commercial landlords
  • Property managers
  • Real estate investors
View all real estate legislation

Key Operational Considerations

  • 1New Annual Filing: This is a digital data transmission, not a paper form. Systems must be programmed to auto-generate this report annually upon certification of the appraisal roll.

Estimated Cost Impact

lowMinimal cost impact anticipated.

Enforcing Agencies

Need Government Relations Support?

JD Key Consulting provides government affairs and regulatory strategy services. We help businesses navigate Texas agencies, understand legislative impacts, and advocate for their interests.

Need Help Navigating This Legislation?

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

HB851
Relating to the determination and reporting of the number of residence homesteads of certain property owners for which the owner is receiving certain ...
Low Urgency
Unanimous Passage
House Vote145 - 0
YEA
100% in favor145 voting
Senate Vote31 - 0
YEA
100% in favor31 voting
Cost Impact
Low
Effective
2026-01-01
Enforcing Agencies
Comptroller of Public AccountsCounty Appraisal Districts
Primary Author: Rep. Mike Schofield
89th Texas Legislature
jdkey.com
01

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

  • Effective Date: January 1, 2026
  • Compliance Deadline: July 25, 2026 (Approximate). The first report is due concurrently with the submission of the certified appraisal roll to the county assessor-collector.
  • Agency Rulemaking: The Comptroller of Public Accounts must prescribe the "form and manner" of this report. Expect technical specifications (file layouts/XML schemas) to be released by Q4 2025.

Immediate Action Plan

  • 1. Software Audit (Immediate): Verify that your current database fields accurately distinguish between Section 33.06 and 33.065 deferrals. If these are currently lumped into a generic "Deferral" code, data remediation is required immediately.
  • 2. Vendor Notification (Q3 2025): CADs must formally notify their CAMA software providers of the HB851 requirement to ensure it is on the development roadmap for the 2026 release.
  • 3. Monitor PTAD (Q4 2025): Assign a compliance officer to monitor the Comptroller’s website for the release of the reporting file layout.
  • 4. Dry Run (May 2026): Conduct a test generation of the report using preliminary 2026 appraisal data to ensure the PII filter is functioning correctly before the July deadline.

Operational Changes Required

Contracts

  • Software Service Agreements: CADs must review current software maintenance contracts. If "legislative updates" are included, vendors must implement this reporting module at no cost. If not, vendors may issue change orders for custom development.
  • Indemnification Clauses: Vendors providing this reporting tool should face stricter indemnification requirements regarding PII. If the software accidentally scrapes names or addresses along with the aggregate data, the vendor must bear the liability for the privacy breach.

Hiring/Training

  • IT & Database Administrators: No new hires are required, but existing IT staff must be trained on the specific query logic required to isolate Section 11.26 (tax ceiling), Section 33.06 (elderly/disabled deferrals), and Section 33.065 (appreciating value deferrals) data sets.

Reporting & Record-Keeping

  • New Annual Filing: This is a digital data transmission, not a paper form. Systems must be programmed to auto-generate this report annually upon certification of the appraisal roll.
  • Data Segmentation: Databases must now permanently categorize and count deferrals *by school district*.
  • Privacy Validation: A mandatory "scrubbing" protocol must be implemented to verify that no PII is included in the transmission to the Comptroller.

Fees & Costs

  • Development Costs: Software vendors will incur one-time development costs to build the reporting module.
  • No Statutory Fees: The bill does not impose new filing fees on property owners or districts.

Strategic Ambiguities & Considerations

1. Data Suppression Standards:

The law strictly prohibits PII. However, in rural school districts with very low populations, reporting a count of "1" for a specific medical deferral could inadvertently identify the homeowner. The Comptroller has not yet clarified if districts should use data suppression techniques (e.g., reporting "<5" instead of exact numbers) for small data sets.

2. Technical File Specifications:

The statute requires reporting but does not define the format (CSV, XML, JSON). Until the Comptroller’s Property Tax Assistance Division (PTAD) releases the schema, vendors cannot finalize the code.

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
Nov 12, 2024
Passed House
May 8, 2025
Passed Senate
May 25, 2025
Signed
Jun 20, 2025
Effective
Jan 1, 2026
TopicsAgingDisabilities, Persons WithMilitary & VeteransTaxationTaxation--property-appraisals & Appraisal DistrictsTaxation--property-assessment & CollectionTaxation--property-exemptionsTaxation--property-state AdministrationTaxation--school DistrictProperty InterestsProperty Interests--homesteadComptroller of Public Accounts
03

House Authors

Rep. Mike SchofieldRepublican · Primary Author

Senate Sponsors

Sen. Paul BettencourtRepublican · Primary Sponsor
Cosponsors (1)

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. Mike Schofield

View all bills by Rep. Mike Schofield

Related by Topic

View more Aging legislation
Quick Reference

Frequently Asked Questions

Common questions about HB851

Q

What does Texas HB851 do?

HB851 mandates that County Appraisal Districts (CADs) aggregate and report specific homestead data—specifically regarding tax ceilings, deferrals, and abatements—to the State Comptroller annually. While the statutory burden lies with Chief Appraisers, the operational burden falls squarely on government software vendors and IT directors, who must reconfigure CAMA (Computer-Assisted Mass Appraisal) systems to generate these reports without transmitting Personal Identifying Information (PII).

Q

Who authored HB851?

HB851 was authored by Texas Representative Mike Schofield during the Regular Session.

Q

When was HB851 signed into law?

HB851 was signed into law by Governor Greg Abbott on June 20, 2025.

Q

Which agencies enforce HB851?

HB851 is enforced by Comptroller of Public Accounts and County Appraisal Districts (Chief Appraisers).

Q

How significant are the changes in HB851?

The regulatory priority for HB851 is rated as "low". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of HB851?

The cost impact of HB851 is estimated as "low". This may vary based on industry and implementation requirements.

Q

What topics does HB851 address?

HB851 addresses topics including aging, disabilities, persons with, military & veterans, taxation and taxation--property-appraisals & appraisal districts.

Q

What are the key dates for HB851?

Key dates for HB851: Effective date is 2026-01-01. Rulemaking: Must prescribe the form and manner for Chief Appraisers to report homestead data (per Bill Analysis). (Prior to 2026 Tax Year Reporting Cycle). Consult with legal counsel regarding applicability.

Q

Which Texas businesses are affected by HB851?

HB851 primarily affects property owners and real estate professionals. 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