Relating to reforming the procedure by which state agencies adopt rules and impose regulatory requirements and the deference given to the interpretation of laws and rules by state agencies in certain judicial proceedings.

Contracts

• "Compliance with Law" Clauses: Review Master Service Agreements (MSAs) and vendor contracts. Ensure you are not contractually bound to adhere to "agency guidance" or "interpretations" that may be struck down under the new *de novo* review standard.
• Government Contracting: Watch for new RFPs requiring vendors to provide "economic impact data." Agencies may attempt to shift the burden of their new statutory cost-analysis requirements onto contractors.

Hiring/Training

• Legal Counsel: Instruct outside counsel that for any suit filed on or after September 1, 2025, they must demand de novo review. They must stop relying on agency deference in briefs.
• Compliance Teams: Train staff to scrutinize the "Fiscal Note" of newly proposed rules. If an agency claims "no fiscal impact," your team must be prepared to submit contradictory data during the comment period to preserve the record for litigation.

Reporting & Record-Keeping

• Cost Tracking: Implement internal tracking to segregate and quantify the specific costs of regulatory compliance (e.g., hours spent on forms, consultant fees). This data is now required evidence if you petition the TREO for rule repeal or challenge a rule's validity in court.
• Form Audits: Compile a list of redundant or complex state forms. You will need this inventory to submit to the TREO once the "Rulemaking and Regulatory Efficiency Forum" is established in 2026.

Fees & Costs

• No New Fees: The bill does not impose new fees on business.
• Fee Reduction: The law mandates agencies identify opportunities to reduce or eliminate fees. Monitor the TREO website (launching 2026, subject to appropriation) for opportunities to petition for specific fee relief.