Regular Session
Government Affairs & Regulatory Compliance Analysis
SB2 establishes a state-funded Education Savings Account (ESA) program managed by the Comptroller of Public Accounts, shifting public funds to private vendors and schools starting the 2026-2027 school year. Private schools, ed-tech vendors, and service providers must obtain regulatory preapproval, submit to state audits, and adhere to strict pricing controls to accept these funds.
Sen. Charles Creighton·Senate Bill·Regular Session
Comptroller of Public Accounts • Local District Attorneys • State Auditor's Office • Texas Education Agency (TEA)
This legislation has regulatory implications for the following Texas businesses and organizations:
Significant regulatory changes (effective 2025-09-01). Review with your legal and compliance teams to understand implications.
Affected business types:
highSignificant operational investment may be required.
JD Key Consulting provides government affairs and regulatory strategy services. We help businesses navigate Texas agencies, understand legislative impacts, and advocate for their interests.
JD Key Consulting provides strategic guidance on Texas regulatory compliance and legislative impact for your business.
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.
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 SB2
SB2 establishes a state-funded Education Savings Account (ESA) program managed by the Comptroller of Public Accounts, shifting public funds to private vendors and schools starting the 2026-2027 school year. Private schools, ed-tech vendors, and service providers must obtain regulatory preapproval, submit to state audits, and adhere to strict pricing controls to accept these funds.
SB2 was authored by Texas Senator Charles Creighton during the Regular Session.
SB2 was signed into law by Governor Greg Abbott on May 3, 2025.
SB2 is enforced by Comptroller of Public Accounts, Local District Attorneys, State Auditor's Office and Texas Education Agency (TEA).
The regulatory priority for SB2 is rated as "critical". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of SB2 is estimated as "high". This may vary based on industry and implementation requirements.
SB2 addresses topics including education, education--primary & secondary, education--primary & secondary--finance, education--higher and education--higher--general.
Key dates for SB2: Effective date is 2025-09-01. Rulemaking: Adopt rules necessary to implement, administer, and enforce Subchapter J, including application processes and provider preapproval. (2026-05-15); May adopt emergency rules to facilitate the 2026-2027 school year launch without standard findings of imminent peril. (Emergency Basis (Optional)). Consult with legal counsel regarding applicab
SB2 establishes the following penalties: administrative penalty of Suspension/Removal for Provider or vendor ineligibility or failure to comply with program requirements.; civil/administrative penalty of Recovery of funds plus interest for Use of program funds for unallowed expenses or by ineligible participants/providers.; criminal penalty of Prosecution (Referral to DA) for Fraudulent use of an account or money distributed under the program.. 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.
