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.
LowStandard timeline
Low Cost
Effective:2026-01-01
Enforcing Agencies
Comptroller of Public Accounts • County Appraisal Districts (Chief Appraisers)
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.
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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.
Texas homeowners who are over the age of 65, have at least one qualifying disability, or are disabled veterans are entitled to a limitation on the total amount of property taxes that school districts may impose on their properties. However, the bill author has informed the committee that the state currently lacks comprehensive data on how many qualifying homestead owners are eligible for these limitations and how many actually utilize them, which hinders the development of policies that effectively serve the interests of both the state and its homeowners. H.B. 851 seeks to address the issue by requiring the comptroller of public accounts to annually report the number of residence homesteads of certain property owners for which the owners are receiving certain property tax benefits.
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
H.B. 851 amends the Tax Code to require the chief appraiser of an appraisal district, for each public school district in the appraisal district, to report, not later than September 1 of the applicable tax year, to the comptroller of public accounts in a form prescribed by the comptroller the following numbers, as determined by the chief appraiser:
·residence homesteads of individuals who are elderly or disabled that are subject to the limitation on school district tax increases for such individuals for the current tax year;
·residence homesteads of individuals who are elderly or disabled or disabled veterans for which a property owner deferred collection of a tax, abated a suit to collect a delinquent tax, or abated a sale to foreclose a tax lien during any portion of the preceding tax year; and
·appreciating residence homesteads for which a property owner deferred or abated a suit to collect a delinquent tax during any portion of the preceding tax year.
H.B. 851 requires the comptroller, not later than November 1 of each tax year, to report to the lieutenant governor, the speaker of the house of representatives, and each member of the legislature the total number of residence homesteads as collected by the comptroller under the bill's provisions. The bill requires such reports to include the number of the applicable residence homesteads in each school district or a reference to where the information for each school district may be accessed.
H.B. 851 applies only to the determination and reporting of information during a tax year beginning on or after the bill's effective date.
Honorable Morgan Meyer, Chair, House Committee on Ways & Means
FROM:
Jerry McGinty, Director, Legislative Budget Board
IN RE:
HB851 by Schofield (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.), As Introduced
No significant fiscal implication to the State is anticipated.
The bill would require the chief appraiser to determine the number of residence homesteads subject to the tax limitation in each school district and report that number to the comptroller annually.
The bill would require the chief appraiser to determine the number of residence homesteads subject to a deferral or abatement for a person aged 65 or older, disabled, or a disabled veteran and the number of residence homesteads subject to a deferral or abatement due to appreciating value in each school district and report that number to the comptroller annually.
The comptroller would be required to provide the legislature with a report each year detailing the information provided by the chief appraiser as provided by the bill.
Local Government Impact
No significant fiscal implication to units of local government is anticipated.
Source Agencies:
304 Comptroller of Public Accounts
LBB Staff:
JMc, KK, SD, BRI
Related Legislation
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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). Implementation Timeline Effective Date: January 1, 2026 Compliance Deadline: July 25, 2026 (Approximate).
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 urgent is compliance with HB851?
The compliance urgency for HB851 is rated as "low". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
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.
Legislative data provided by LegiScanLast updated: November 25, 2025
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