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Signed Into Law
Signed June 20, 2025Effective 2025-09-01
SB2167

Regular Session

Relating to the licensing and regulation of massage therapy.

Government Affairs & Regulatory Compliance Analysis

SB2167: Government Affairs Overview

Effective September 1, 2025, massage establishments can no longer transfer licenses to new locations; moving a facility now triggers a requirement for a completely new license application and full fee. Additionally, the Texas Department of Licensing and Regulation (TDLR) gains broad authority to delay licensure for up to 90 days based on "reasonable cause" to suspect human trafficking activity by any owner or operator, significantly increasing operational risk during renewals and acquisitions.

Sen. Angela Paxton·Senate Bill·Regular Session

Moderate
Medium Cost
Effective:2025-09-01

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SB2167
Moderate
Relating to the licensing and regulation of massage therapy.
Moderate Compliance Urgency
Requires near-term attention
Cost Impact
Medium
Effective
2025-09-01
Enforcing Agencies
County AttorneysDistrict AttorneysMunicipal AttorneysTCLR+1 more
Primary Author: Sen. Angela Paxton
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: August 15, 2025 (Recommended deadline to submit any pending location change requests under current rules to avoid new licensure requirements).
  • Agency Rulemaking: TDLR is required to adopt rules "as soon as practicable" after the effective date. Warning: A regulatory gray zone will exist between September 1 and final rule adoption where "reasonable cause" for delays is undefined.

Immediate Action Plan

  • 1. Freeze Moves: If you are planning a location change, submit the application before August 31, 2025, to utilize the current transfer process.
  • 2. Audit Personnel: Immediately vet all minority owners and site managers for any history of regulatory friction regarding sexual offenses or trafficking; remove flagged individuals from "operator" roles before your next renewal.
  • 3. Update Leases: Insert regulatory contingency clauses into all active lease negotiations immediately.
  • 4. Prepare for Local Enforcement: Brief facility managers that local law enforcement and city attorneys now have a financial incentive to inspect and fine; strict adherence to daily compliance protocols is mandatory.

Operational Changes Required

Contracts

  • Commercial Leases: You must update lease agreements for new locations. Do not agree to a fixed Rent Commencement Date. Instead, tie rent commencement to the issuance of the state license, citing the potential for statutory 90-day administrative delays under SB2167.
  • M&A Agreements: Asset Purchase Agreements must include specific indemnification for revenue lost due to licensure delays caused by the seller’s historical conduct.

Hiring/Training

  • Enhanced Vetting: The definition of "Applicant" for delay purposes includes "operators." You must run background checks on all site managers and supervisors specifically for Chapter 20A (Trafficking of Persons) offenses. A manager's past can now stall your corporate license.

Reporting & Record-Keeping

  • Compliance Logs: Local prosecutors now have a direct financial incentive (civil penalties go to local funds) to pursue enforcement. Ensure on-site logs—therapist licenses, sanitation records, and intake forms—are audit-ready at all times to prevent triggering a "reasonable cause" investigation.

Fees & Costs

  • Licensing Fees: Budget for full "Initial Application" fees rather than "Change of Location" fees for any facility move.
  • Holding Costs: Budget for 3-4 months of operational carrying costs (rent/staff retention) during potential licensure delays if your entity is flagged for review.

Strategic Ambiguities & Considerations

"Reasonable Cause" is currently undefined.

The statute allows TDLR to delay a license if the Executive Director has "reasonable cause" to believe trafficking is occurring or has occurred. It does not specify the evidentiary standard.

  • *Risk:* Could an anonymous complaint or a clerical error on an intake form constitute "reasonable cause"?
  • *Watch:* Monitor the Texas Register for TDLR proposed rules defining the threshold for these delays. We must advocate for a clear evidentiary standard during the comment period.

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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 10, 2025
Passed Senate
Apr 24, 2025
Passed House
May 27, 2025
Signed
Jun 20, 2025
Effective
Sep 1, 2025
TopicsOccupational RegulationOccupational Regulation--other Trades & ProfessionsMassage Therapy & Massage TherapistsLicensing & Regulation, Texas Commission of
03

Senate Authors

Sen. Angela PaxtonRepublican · Primary Author

House Sponsors

Rep. Ben BumgarnerRepublican · Primary Sponsor
Joint Sponsors

Bill Text(with markup)

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

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Quick Reference

Frequently Asked Questions

Common questions about SB2167

Q

What does Texas SB2167 do?

Effective September 1, 2025, massage establishments can no longer transfer licenses to new locations; moving a facility now triggers a requirement for a completely new license application and full fee. Additionally, the Texas Department of Licensing and Regulation (TDLR) gains broad authority to delay licensure for up to 90 days based on "reasonable cause" to suspect human trafficking activity by any owner or operator, significantly increasing operational risk during renewals and acquisitions.

Q

Who authored SB2167?

SB2167 was authored by Texas Senator Angela Paxton during the Regular Session.

Q

When was SB2167 signed into law?

SB2167 was signed into law by Governor Greg Abbott on June 20, 2025.

Q

Which agencies enforce SB2167?

SB2167 is enforced by County Attorneys, District Attorneys, Municipal Attorneys, Texas Commission of Licensing and Regulation (TCLR) and Texas Department of Licensing and Regulation (TDLR).

Q

How significant are the changes in SB2167?

The regulatory priority for SB2167 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of SB2167?

The cost impact of SB2167 is estimated as "medium". This may vary based on industry and implementation requirements.

Q

What topics does SB2167 address?

SB2167 addresses topics including occupational regulation, occupational regulation--other trades & professions, massage therapy & massage therapists and licensing & regulation, texas commission of.

Q

What are the key dates for SB2167?

Key dates for SB2167: Effective date is 2025-09-01. Rulemaking: Adopt rules necessary to implement changes to Chapter 455, specifically regarding license delays and location changes. (As soon as practicable after 2025-09-01). Consult with legal counsel regarding applicability.

Q

What are the penalties under SB2167?

SB2167 establishes the following penalties: administrative penalty of Indefinite delay for Applicant (or owner/operator) is subject to an active emergency order regarding human trafficking or sexual offenses.; administrative penalty of Up to 90-day delay in application determination for Reasonable cause to believe human trafficking is occurring/likely at the location, or was committed at a location owned/operated by the applicant.; civil penalty of Variable (Civil Penalty Disposition Change) for Civil penalties recovered by local prosecutors are now strictly earmarked for local general funds to combat human trafficking, incentivizing increased local enforcement.. Consult with legal counsel for specific applicability to your situation.

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