Regular Session
Government Affairs & Regulatory Compliance Analysis
SB1964 fundamentally alters Texas public sector procurement by mandating strict adherence to the NIST AI Risk Management Framework for any vendor providing "Heightened Scrutiny" AI systems to state agencies, cities, or counties. Failure to comply triggers mandatory contract termination and potential statewide debarment, effectively barring your business from the Texas public sector market.
Sen. Tan Parker·Senate Bill·Regular Session
Comptroller of Public Accounts • Department of Information Resources (DIR) • Individual State Agencies (Contract Managers) • Office of the Attorney General (OAG)
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Key implementation requirements and action items for compliance with 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.
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This bill's path through the Texas Legislature
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Common questions about SB1964
SB1964 fundamentally alters Texas public sector procurement by mandating strict adherence to the NIST AI Risk Management Framework for any vendor providing "Heightened Scrutiny" AI systems to state agencies, cities, or counties. Failure to comply triggers mandatory contract termination and potential statewide debarment, effectively barring your business from the Texas public sector market.
SB1964 was authored by Texas Senator Tan Parker during the Regular Session.
SB1964 was signed into law by Governor Greg Abbott on June 20, 2025.
SB1964 is enforced by Comptroller of Public Accounts, Department of Information Resources (DIR), Individual State Agencies (Contract Managers) and Office of the Attorney General (OAG).
The regulatory priority for SB1964 is rated as "critical". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of SB1964 is estimated as "medium". This may vary based on industry and implementation requirements.
SB1964 addresses topics including artificial intelligence, city government, city government--general, county government and county government--general.
Key dates for SB1964: Effective date is 2025-09-01. Rulemaking: Adopt rules implementing Subchapter S, establish AI Code of Ethics, and develop Minimum Risk Management Standards (aligned with NIST AI RMF 1.0). (As soon as practicable after 2025-09-01); Develop standardized public notice forms for AI systems. (As soon as practicable after 2025-09-01). Consult with legal counsel regarding applicabil
SB1964 establishes the following penalties: administrative penalty of Contract Termination for Vendor failure to cure a violation of the AI statutes within 31 days of notice from the Attorney General, followed by a failure to cure within 31 days of notice of intent to void from the Agency.; administrative penalty of Debarment (Barred from State Contracting) for Vendor having more than one contract voided due to AI statute violations (determined by Comptroller).. 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.
