JD Key Consulting Logo
Signed Into Law
Signed June 20, 2025Effective 2025-09-01
SB2073

Regular Session

Relating to the authority of an appraisal district to purchase, finance the purchase of, or lease real property or construct or finance the construction of improvements to real property.

Government Affairs & Regulatory Compliance Analysis

SB2073: Government Affairs Overview

SB 2073 reverses the approval presumption for Appraisal District (CAD) real estate transactions: effective September 1, 2025, a taxing unit's silence constitutes legal consent, not rejection. This legislation primarily impacts cities, counties, and school districts, requiring immediate action to actively disapprove proposed acquisitions or renovations within a strict 30-day window, while simultaneously streamlining the lending process for financial institutions servicing CADs.

Sen. Judith Zaffirini·Senate Bill·Regular Session

Moderate
Low Cost
Effective:2025-09-01
Enforcing Agencies

Appraisal District Board of Directors • Governing Bodies of Taxing Units (Cities, Counties, School Districts, Special Districts)

Business Impact

Who SB2073 Affects

This legislation has regulatory implications for the following Texas businesses and organizations:

Regulatory Priority: moderate

Notable regulatory updates (effective 2025-09-01). Consider how these changes may affect your operations.

🏢

Real Estate

Affected business types:

  • Property developers
  • Commercial landlords
  • Property managers
  • Real estate investors
View all real estate legislation

Key Operational Considerations

  • 1Administrative Intake: City Managers, Superintendents, and County Clerks must train administrative staff to flag mail from the Chief Appraiser as "High Priority/Time Sensitive."

Estimated Cost Impact

lowMinimal cost impact anticipated.

Need Government Relations Support?

JD Key Consulting provides government affairs and regulatory strategy services. We help businesses navigate Texas agencies, understand legislative impacts, and advocate for their interests.

Need Help Navigating This Legislation?

JD Key Consulting provides strategic guidance on Texas regulatory compliance and legislative impact for your business.

SB2073
Moderate
Relating to the authority of an appraisal district to purchase, finance the purchase of, or lease real property or construct or finance the constructi...
Moderate Compliance Urgency
Requires near-term attention
Cost Impact
Low
Effective
2025-09-01
Enforcing Agencies
Appraisal District Board of Dire...Governing Bodies of Taxing Units
Primary Author: Sen. Judith Zaffirini
89th Texas Legislature
jdkey.com
01

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

  • Effective Date: September 1, 2025
  • Compliance Deadline: September 1, 2025 (Applies to any notification sent by a Chief Appraiser on or after this date).
  • Agency Rulemaking: No state-level rulemaking is required. However, Appraisal District Boards and Taxing Unit Governing Bodies must update internal bylaws and notice protocols prior to Q3 2025 to manage the new deadlines.

Immediate Action Plan

  • Update Mail Protocols: Reclassify correspondence from the Chief Appraiser as time-sensitive legal notices immediately.
  • Revise Board Agendas: Create a standing rule that CAD real estate proposals are automatically placed on the next available agenda; "tabling" the item is now a liability.
  • Standardize Disapproval: Draft a template "Resolution of Disapproval" to keep on file for rapid deployment.
  • Engage CAD Boards: Request a written policy from your local CAD defining what constitutes a "renovation" versus standard maintenance to avoid procedural confusion.

Operational Changes Required

Contracts

  • Lending Agreements: Commercial lenders may remove clauses requiring proof of 75% taxing unit approval for *financing* terms. Due diligence is now limited to verifying the *project* approval (or proof of non-rejection).
  • Real Estate PSAs: Purchase and Sale Agreements involving CADs should align "Governmental Approval" contingency periods with the new 40-day statutory finality window (30 days for action + 10 days for filing).

Hiring/Training

  • Administrative Intake: City Managers, Superintendents, and County Clerks must train administrative staff to flag mail from the Chief Appraiser as "High Priority/Time Sensitive."
  • Legal Counsel: In-house counsel for taxing units must be briefed to draft "Resolutions of Disapproval" immediately upon receipt of a proposal, as the default "wait and see" approach now results in automatic approval.

Reporting & Record-Keeping

  • Proof of Filing: Taxing units must implement a certified mail or courier protocol to ensure "Resolutions of Disapproval" are filed with the Chief Appraiser by the 40th day (10 days after the 30-day action period). Failure to prove delivery invalidates the vote.
  • Alternative Cost Analysis: Chief Appraisers must now generate and file a cost analysis of alternatives alongside any acquisition proposal.

Fees & Costs

  • Budgetary Risk: No new statutory filing fees. However, taxing units face significant unbudgeted capital costs if they miss the 30-day deadline and are forced to fund their share of a CAD’s real estate acquisition by operation of law.

Strategic Ambiguities & Considerations

  • "Costs of Other Available Alternatives": The statute mandates the Chief Appraiser provide cost comparisons but fails to define the depth of this analysis (e.g., full market study vs. simple estimate). Taxing units should establish a standard for sufficiency now to prevent disputes over vague proposals.
  • Definition of "Renovation": The law applies to "renovation" but sets no monetary threshold. It is unclear if minor capital improvements (e.g., HVAC replacement) trigger this process or if it is reserved for major structural changes.

Need Compliance Guidance on 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 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.

02

Legislative Timeline

This bill's path through the Texas Legislature

Filed
Mar 7, 2025
Passed Senate
Apr 24, 2025
Passed House
May 28, 2025
Signed
Jun 20, 2025
Effective
Sep 1, 2025
TopicsProperty InterestsProperty Interests--real PropertyTaxationTaxation--property-appraisals & Appraisal Districts
03

Senate Authors

Sen. Judith ZaffiriniDemocrat · Primary Author

House Sponsor

Rep. Ryan GuillenRepublican · Primary Sponsor

Bill Text(with markup)

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

Related Legislation

Explore more bills from this author and on related topics

More from Sen. Judith Zaffirini

View all bills by Sen. Judith Zaffirini

Related by Topic

View more Property Interests legislation
Quick Reference

Frequently Asked Questions

Common questions about SB2073

Q

What does Texas SB2073 do?

SB 2073 reverses the approval presumption for Appraisal District (CAD) real estate transactions: effective September 1, 2025, a taxing unit's silence constitutes legal consent, not rejection. This legislation primarily impacts cities, counties, and school districts, requiring immediate action to actively disapprove proposed acquisitions or renovations within a strict 30-day window, while simultaneously streamlining the lending process for financial institutions servicing CADs.

Q

Who authored SB2073?

SB2073 was authored by Texas Senator Judith Zaffirini during the Regular Session.

Q

When was SB2073 signed into law?

SB2073 was signed into law by Governor Greg Abbott on June 20, 2025.

Q

Which agencies enforce SB2073?

SB2073 is enforced by Appraisal District Board of Directors and Governing Bodies of Taxing Units (Cities, Counties, School Districts, Special Districts).

Q

How significant are the changes in SB2073?

The regulatory priority for SB2073 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of SB2073?

The cost impact of SB2073 is estimated as "low". This may vary based on industry and implementation requirements.

Q

What topics does SB2073 address?

SB2073 addresses topics including property interests, property interests--real property, taxation and taxation--property-appraisals & appraisal districts.

Q

What are the key dates for SB2073?

Key dates for SB2073: Effective date is 2025-09-01. Consult with legal counsel regarding applicability.

Q

Which Texas businesses are affected by SB2073?

SB2073 primarily affects property owners and real estate professionals. These businesses should review the legislation with their legal and compliance teams to understand potential impacts.

Need Strategic Guidance on This Legislation?

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.

Legislative data provided by LegiScanLast updated: January 11, 2026