SB1951

Regular Session

Relating to the imposition of a penalty for failure to timely file a rendition statement or property report with the chief appraiser of an appraisal district.

ModeratePlan for compliance

Low Cost

Effective:2026-01-01

Enforcing Agencies

Chief Appraiser (County Appraisal Districts) • Tax Assessor-Collectors

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

Effective Date: January 1, 2026
Compliance Deadline: April 15, 2026 (Deadline to file renditions to avoid the automated penalty cycle).
Agency Rulemaking: While no new agency rules are mandated, the Comptroller may update model forms prior to the 2026 tax year. Monitor the Comptroller’s Property Tax Assistance Division for updated Rendition Penalty Notice templates in late 2025.

Immediate Action Plan

1. Audit Lease Agreements: Review all NNN leases before the 2026 tax year to clarify liability for administrative tax penalties.
2. Update AP Software: Configure ERP/Accounting systems to require a manual check if a property tax bill exceeds the prior year's amount by 10% or more.
3. Establish "June 1" Watchlist: Calendar a compliance check for the first week of June 2026 to verify receipt (or non-receipt) of penalty notices.
4. Verify Asset Rolls: For any notice received via Certified Mail, immediately cross-reference asset lists to determine if a location was erroneously dropped from the rolls in the prior year.

Operational Changes Required

Contracts

NNN Leases (Tenants): Amend lease terms to explicitly exclude reimbursement for "penalties resulting from Landlord’s failure to timely render." You must not pay for the landlord's administrative errors now that they are line-itemized.
NNN Leases (Landlords): Ensure "Operating Expenses" definitions are broad enough to capture penalties if the tenant is contractually responsible for the filing but fails to perform.
Tax Consultant MSAs: Update indemnity clauses. If a third-party vendor misses a filing, they must be liable for the 10% penalty, which will now be irrefutably documented on the tax bill.

Hiring/Training

Accounts Payable: Train AP staff to review tax bills for the specific "Penalty" line item. Do not auto-pay bills containing this line item without Legal/Tax review.
Mailroom Protocols: Staff must be trained to flag Certified Mail from Appraisal Districts received between May 15 and June 5. This specific mail class indicates the property was omitted from the prior year's roll, signaling a high-risk audit scenario.

Reporting & Record-Keeping

Proof of Filing: Maintain digital logs or certified mail receipts for all April rendition filings. The automated June 1 notice requirement removes informal leniency; you will need documented proof of timely filing to contest a penalty.

Fees & Costs

Penalty Structure: 10% of the total tax liability for the year.
Budget Impact: While the penalty amount is unchanged, the likelihood of assessment is higher due to automated notification requirements.

Strategic Ambiguities & Considerations

The "June 1" vs. "Value Notice" Conflict: The statute requires the penalty notice be delivered "with the notice of appraised value" by June 1. However, Appraisal Districts frequently delay value notices past June 1.
*Business Logic:* If a penalty notice arrives *after* June 1, Legal Counsel should protest the penalty on procedural grounds, arguing the Chief Appraiser failed to meet the statutory deadline, rendering the penalty invalid.
Enforcement Incentives: The bill removes the 5% revenue share previously kept by Appraisal Districts. With no financial incentive to collect the penalty, Appraisal Districts may become administratively lax, but Taxing Units (who now keep 100% of the penalty) will likely exert political pressure for maximum enforcement.

Need Help Understanding Implementation?

Our government affairs experts can walk you through this bill's specific impact on your operations.

Schedule 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.

Legislative Timeline

This bill's path through the Texas Legislature

TopicsTaxation Taxation--property-appraisals & Appraisal Districts

Official Analysis

View HRO Analysis View All Bill Documents

BILL ANALYSIS

Senate Research Center	S.B. 1951
89R3779 LHC-F	By: Paxton
	Local Government
	3/28/2025
	As Filed

AUTHOR'S / SPONSOR'S STATEMENT OF INTENT

S.B. 1951 provides additional transparency and taxpayer notice requirements with respect to late rendition penalties and removes the financial incentive for appraisal districts to impose such penalties.

A 10 percent penalty is imposed on any taxpayer who fails to timely file a personal property rendition statement or property report. The appraisal district imposing the penalty is required to send notice of the penalty to the taxpayer via first class mail, though there is no statutory deadline for doing so. Notably, appraisal districts also get to keep five percent of all rendition penalties they impose each year.

In addition, some appraisal districts are imposing rendition penalties without taxpayers ever having any knowledge of it. These taxpayers never receive a penalty notice in the mail and may have no idea a penalty was levied because the penalty is embedded in the "tax due" amount on the tax bill (without any itemization or reference to the penalty). As a result, taxpayers may have no idea they are paying a 10 percent penalty they may not owe.

As proposed, S.B. 1951 amends current law relating to the imposition of a penalty for failure to timely file a rendition statement or property report with the chief appraiser of an appraisal district.

RULEMAKING AUTHORITY

This bill does not expressly grant any additional rulemaking authority to a state officer, institution, or agency.

SECTION BY SECTION ANALYSIS

SECTION 1.� Sections 22.28(a) and (b), Tax Code, are amended to read as follows:

(a)� Requires the chief appraiser, not later than June 1, to deliver by certified mail, rather than first class mail, a notice of the imposition of a penalty to a person who fails to timely file a rendition statement or property report. Requires that the notice also be delivered, rather than authorizes that the notice, if practicable, be delivered, with a notice of appraised value provided under Section 25.19 (Notice of Appraised Value). Makes a nonsubstantive change.

(b) Requires that the tax bill state the amount of tax due and the amount of the penalty due as separate line items.

SECTION 2. Repealer: Section 22.28(d) (relating to the requirement that five percent of the imposed penalty amount be remitted to the appraisal district), Tax Code.

SECTION 3.� Makes application of this Act prospective.

SECTION 4.� Effective date: January 1, 2026.

Senate Authors

Sen. Angela PaxtonRepublican · Primary Author

House Sponsor

Rep. Angie ButtonRepublican · Primary Sponsor

Bill Text(with markup)

S.B. No. 1951

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

	AN ACT
	relating to the imposition of a penalty for failure to timely file a
	rendition statement or property report with the chief appraiser of
	an appraisal district.
	BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF TEXAS:
	SECTION 1. Sections 22.28(a) and (b), Tax Code, are amended
	to read as follows:
	(a) Except as otherwise provided by Section 22.30, the chief
	appraiser shall impose a penalty on a person who fails to timely
	file a rendition statement or property report required by this
	chapter in an amount equal to 10 percent of the total amount of
	taxes imposed on the property for that year by taxing units
	participating in the appraisal district. Not later than June 1, the
	[~~The~~] chief appraiser shall deliver [~~by first class mail~~] a notice
	of the imposition of the penalty to the person. The notice must be
	delivered by first-class mail, except that the notice must be
	delivered by certified mail if the property was not listed on the
	appraisal roll in the preceding tax year. The notice must also
	[~~may~~] be delivered with a notice of appraised value provided under
	Section 25.19[~~, if practicable~~].
	(b) The chief appraiser shall certify to the assessor for
	each taxing unit participating in the appraisal district that
	imposes taxes on the property that a penalty imposed under this
	chapter has become final. The assessor shall add the amount of the
	penalty to the original amount of tax imposed on the property and
	shall include that amount in the tax bill for that year. The tax
	bill must state the amount of tax due and the amount of the penalty
	due as separate line items. The penalty becomes part of the tax on
	the property and is secured by the tax lien that attaches to the
	property under Section 32.01.
	SECTION 2. Section 22.28(d), Tax Code, is repealed.
	SECTION 3. The changes in law made by this Act apply only to
	an ad valorem tax year that begins on or after the effective date of
	this Act.
	SECTION 4. This Act takes effect January 1, 2026.

LEGISLATIVE BUDGET BOARD
Austin, Texas

FISCAL NOTE, 89TH LEGISLATIVE REGULAR SESSION


March 29, 2025

TO:	Honorable Paul Bettencourt, Chair, Senate Committee on Local Government

FROM:	Jerry McGinty, Director, Legislative Budget Board

IN RE:	SB1951 by Paxton (Relating to the imposition of a penalty for failure to timely file a rendition statement or property report with the chief appraiser of an appraisal district.), As Introduced

No fiscal implication to the State is anticipated.

The bill would require a chief appraiser by June 1 to deliver by certified mail a notice of the imposition of penalty to the person for failing to timely file a rendition statement or property report. The notice must also be delivered with a notice of appraised value. This bill would also require the tax assessor, in the tax bill for that year, to state the amount of tax due and the amount of the penalty due as separate line items.

The bill would repeal the provision requiring a tax assessor-collector to remit 5 percent of the penalty collected for failing to timely file to a rendition statement or property report to the appraisal district.

Local Government Impact

Repealing the provision requiring a tax assessor-collector to remit 5 percent of the penalty collected for failing to timely file to a rendition statement or property report to the appraisal district would result in an indeterminate revenue loss to appraisal districts and offsetting increase in penalty revenue for other units of local government.

Source Agencies:

304 Comptroller of Public Accounts

LBB Staff:

JMc, SZ, KK, BRI

Related Legislation

Explore more bills from this author and on related topics

Frequently Asked Questions

Common questions about SB1951

What does Texas SB1951 do?

SB1951 mandates strict transparency and notification protocols for the 10% penalty associated with failure to file Business Personal Property (BPP) renditions. The law forces Chief Appraisers to issue penalty notices by June 1 and requires Tax Assessors to list penalties as a separate line item on tax bills, effectively eliminating the ability for penalties to be hidden within aggregate tax totals. This impacts all entities owning tangible business personal property, particularly those with multi-location footprints or NNN lease structures.

Who authored SB1951?

SB1951 was authored by Texas Senator Angela Paxton during the Regular Session.

When was SB1951 signed into law?

SB1951 was signed into law by Governor Greg Abbott on June 20, 2025.

Which agencies enforce SB1951?

SB1951 is enforced by Chief Appraiser (County Appraisal Districts) and Tax Assessor-Collectors.

How urgent is compliance with SB1951?

The compliance urgency for SB1951 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.

What is the cost impact of SB1951?

The cost impact of SB1951 is estimated as "low". This may vary based on industry and implementation requirements.

What topics does SB1951 address?

SB1951 addresses topics including taxation and taxation--property-appraisals & appraisal districts.

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.