Regular Session
Government Affairs & Regulatory Compliance Analysis
SB2155 fundamentally expands the State Board of Veterinary Medical Examiners' jurisdiction to include business entities and facilities, not just individual practitioners. Effective September 1, 2027, all veterinary clinics, mobile units, and associated Management Services Organizations (MSOs) must hold a facility license to operate in Texas, subjecting corporate owners to direct administrative penalties.
Sen. Charles Perry·Senate Bill·Regular Session
State Board of Veterinary Medical Examiners (TBVME) • State Office of Administrative Hearings (SOAH) • Texas Department of Licensing and Regulation (TDLR) (Temporary administration/oversight)
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Key implementation requirements and action items for compliance with this legislation
The legislation defers the specific definition of "Management Services Organization" to Board rule. This definition will determine which third-party vendors (e.g., HR providers, billing companies, private equity partners) fall under regulatory scrutiny. Additionally, the Board must create distinct standards for different facility types; if they fail to differentiate adequately, mobile units or shelters could be held to impossible brick-and-mortar building standards.
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 SB2155
SB2155 fundamentally expands the State Board of Veterinary Medical Examiners' jurisdiction to include business entities and facilities, not just individual practitioners. Effective September 1, 2027, all veterinary clinics, mobile units, and associated Management Services Organizations (MSOs) must hold a facility license to operate in Texas, subjecting corporate owners to direct administrative penalties.
SB2155 was authored by Texas Senator Charles Perry during the Regular Session.
SB2155 was signed into law by Governor Greg Abbott on June 20, 2025.
SB2155 is enforced by State Board of Veterinary Medical Examiners (TBVME), State Office of Administrative Hearings (SOAH) and Texas Department of Licensing and Regulation (TDLR) (Temporary administration/oversight).
The regulatory priority for SB2155 is rated as "critical". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of SB2155 is estimated as "medium". This may vary based on industry and implementation requirements.
SB2155 addresses topics including animals, electronic information systems, occupational regulation, occupational regulation--other trades & professions and open records.
Key dates for SB2155: Effective date is 2025-09-01. Rulemaking: Adopt rules for general implementation (excluding facility registration) (As soon as practicable after 2025-09-01); Adopt rules and procedures for Subchapter M (Facility Registration and Standards) (2027-03-01). Consult with legal counsel regarding applicability.
SB2155 establishes the following penalties: administrative penalty of Refund capped at amount paid by consumer for Board-ordered refund to consumer in lieu of or in addition to other sanctions; administrative penalty of TBD (Administrative Penalty/License Sanction) for Facility operating without registration; violation of safety/sanitation standards; denying inspection access; administrative penalty of License Suspension/Revocation or Facility Shutdown for Emergency order issued for immediate threat to public health/safety. 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.
