Regular Session
Government Affairs & Regulatory Compliance Analysis
SB1273 centralizes counter-espionage oversight for Texas "Tier 1" universities under a new Higher Education Research Security Council, effective September 1, 2025. While the statutory burden falls on universities, this law imposes strict downstream compliance requirements on private sector partners, defense contractors, and donors regarding foreign influence, funding sources, and intellectual property security.
Sen. Bryan Hughes·Senate Bill·Regular Session
Higher Education Research Security Council • Office of the Attorney General (Report Recipient) • Texas A&M University System (Presiding Officer)
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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Key implementation requirements and action items for compliance with this legislation
All Master Service Agreements (MSAs), Grant Agreements, and IP Licensing contracts with Tier 1 institutions must be amended to include Representations and Warranties certifying that funds and control do not originate from foreign adversaries (China, Russia, Iran, North Korea). Vendors must certify compliance with federal prohibited entity lists (NDAA).
Private research partners and university labs must align HR vetting with the Council's forthcoming standards. This specifically requires "academic history checks" to identify undisclosed foreign affiliations. Research Security Officers (RSOs) must complete mandatory annual training provided by the Council.
Institutions must document compliance to achieve "security excellence" accreditation. Private partners involved in sensitive R&D must maintain audit-ready records of funding sources and personnel affiliations to support the university's confidential annual reporting to the Governor and Attorney General.
While the Legislative Budget Board anticipates no fiscal impact to the state, businesses should budget for increased administrative costs related to enhanced background checks and potential IT upgrades to meet state-mandated "research security and integrity" tool standards.
The law mandates the use of "research security and integrity tools" but does not define the technical specifications or approved vendors. The Council could mandate specific, proprietary software, forcing costly IT migrations for university partners. Additionally, the scope of "academic history checks" is undefined; it is unclear if this requires international investigators to verify foreign undergraduate records, which would significantly delay hiring.
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 SB1273
SB1273 centralizes counter-espionage oversight for Texas "Tier 1" universities under a new Higher Education Research Security Council, effective September 1, 2025. While the statutory burden falls on universities, this law imposes strict downstream compliance requirements on private sector partners, defense contractors, and donors regarding foreign influence, funding sources, and intellectual property security.
SB1273 was authored by Texas Senator Bryan Hughes during the Regular Session.
SB1273 was signed into law by Governor Greg Abbott on May 27, 2025.
SB1273 is enforced by Higher Education Research Security Council, Office of the Attorney General (Report Recipient) and Texas A&M University System (Presiding Officer).
The regulatory priority for SB1273 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of SB1273 is estimated as "low". This may vary based on industry and implementation requirements.
SB1273 addresses topics including education, education--higher, education--higher--institutions & programs, education--higher--state coordination and electronic information systems.
Key dates for SB1273: Effective date is 2025-09-01. Rulemaking: Develop a mandatory research security policy that Tier 1 research institutions must adopt. (Undetermined (Post-Jan 1, 2026)); Establish an accreditation process for security excellence. (Undetermined (Post-Jan 1, 2026)). Consult with legal counsel regarding applicability.
SB1273 establishes the following penalties: administrative penalty of N/A for Failure of a Tier 1 institution to adopt the research security policy developed by the Council (implied compliance requirement).; administrative penalty of Gift Prohibition for Soliciting or accepting gifts/grants from entities in China, Russia, Iran, North Korea, or other designated foreign adversary countries.. Consult with legal counsel for specific applicability to your situation.
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.
