SB2514

Regular Session

Relating to establishing the hostile foreign adversaries unit at the Department of Public Safety and training, prohibitions, and reporting requirements designed to combat foreign influence and foreign adversary operations; creating a criminal offense.

CriticalImmediate action required

Medium Cost

Effective:2025-09-01

Enforcing Agencies

Department of Public Safety (Hostile Foreign Adversaries Unit) • Texas Ethics Commission • Attorney General • Local Prosecuting Attorneys

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

Effective Date: September 1, 2025
Compliance Deadline: March 1, 2025 (Operational "Go-Live"). While the law is effective in September, Section 4 mandates reporting of all interactions occurring on or after March 1, 2025. You must begin tracking interactions on this date.
Agency Rulemaking:
Texas Ethics Commission (TEC): Must prescribe reporting forms immediately upon the effective date. *Gray Zone:* You must track data from March to September 2025 without a finalized form; maintain raw data logs to populate the form later.
Department of Information Resources (DIR): Must adopt rules for cybersecurity training certifications by December 1, 2025.

Immediate Action Plan

Immediately audit your supply chain and investor list for ties to China, Russia, Iran, and North Korea.
By February 28, 2025, establish a "Foreign Contact Log" protocol to capture data for the retroactive reporting period starting March 1.
Issue a directive to all government affairs staff and external lobbyists: "Stop all gifts, travel, and lodging offers to Texas officials if we have any foreign adversary capital backing."
Preserve all executive calendars and emails starting March 1, 2025, to ensure the October 1 "catch-up" report is accurate.

Operational Changes Required

Contracts

Government MSAs: Expect state agencies and local governments to amend Master Service Agreements immediately. They will require indemnification clauses where you certify you are not "acting on behalf of a foreign adversary."
Lobbying Agreements: You must amend contracts with external lobbyists to include a strict "Duty to Report" clause for any foreign contacts, as their failure to report imputes liability to your organization.
Employment Agreements: Update executive and sales contracts to explicitly prohibit offering gifts or travel to public officials if the funding source originates from a designated adversary nation.

Hiring/Training

Cybersecurity Certification: By May 1, 2026, cybersecurity training programs must include modules on "United Front Work Department" tactics. Verify your training vendors are preparing this content.
Internal Training: Staff interacting with government officials must be trained on the specific definition of "foreign adversary" (currently China, Russia, Iran, North Korea) and the strict prohibition on gifts/travel.

Reporting & Record-Keeping

The "Look-Back" Log: You must implement a CRM tag or manual log to track *all* interactions with foreign entities starting March 1, 2025.
Catch-Up Filing: A consolidated report for all interactions between March 1, 2025, and September 1, 2025, must be filed with the TEC by October 1, 2025.
Rolling Disclosures: Ongoing interactions must be reported within 30 days of occurrence.

Fees & Costs

Legal Defense Gap: Review your Directors & Officers (D&O) insurance. Most policies exclude criminal defense costs. Since violations are State Jail Felonies, your current policy likely leaves your officers exposed.
Indirect Costs: Budget for increased legal counsel review of international travel and vendor vetting.

Strategic Ambiguities & Considerations

"Acting on Behalf Of": The statute fails to define the materiality threshold for when a private business person is considered an agent of a foreign adversary. Until DPS issues guidance, assume any individual with formal ties (e.g., CCP party committee membership) to a foreign government is a reportable contact.
"Interaction" Definition: The law requires reporting "each interaction," without a minimum threshold. It is unclear if social media engagement or brief conference greetings count. *Conservative Approach:* Log every substantive communication.
Governor's Designation Power: The Governor may unilaterally designate additional foreign adversaries. The list of prohibited countries is fluid; you must monitor Executive Orders continuously.

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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.

Legislative Timeline

This bill's path through the Texas Legislature

TopicsCrimes Crimes--miscellaneous Governor Intergovernmental Relations Law Enforcement State Employees International Relations Staff Development & Training Terrorism & Internal Security Ethics Commission, Texas Public Safety, Department of State Agencies, Boards & Commissions Information Resources, Department of Public Safety Commission

Official Analysis

View HRO Analysis View All Bill Documents

BILL ANALYSIS

Senate Research Center	S.B. 2514
	By: Hughes
	State Affairs
	4/11/2025
	As Filed

AUTHOR'S / SPONSOR'S STATEMENT OF INTENT

S.B. 2514 addresses the issue of foreign adversary political warfare and influence operations within Texas.

The Office of the Director of National Intelligence (ODNI) has identified American state and local governments as targets of influence operations conducted by foreign adversaries such as the Chinese Communist Party (CCP). In the 2022 memo "Protecting Government and Business Leaders at the U.S. State and Local Level from People's Republic of China Influence Operations," the ODNI explains that such influence operations seek to collect data, target and cultivate officials, exploit partnerships, create dependencies, and shape policy through the business community.

Foreign adversaries conduct these influence operations at the subnational level to exploit the gap in national security focus between the U.S. federal and subnational governments. Thus, adversaries seek to "use the local to surround the central" by aligning U.S. subnational governments with the foreign policy priorities of foreign adversaries like the CCP.

Research from 2019 from the Jamestown Foundation found that such subnational influence operations accelerated when the CCP failed to achieve its policy goals at the federal level.

S.B. 2514 creates a range of protections to counter foreign adversary influence operations. This bill creates a Hostile Foreign Organizations Unit within the Department of Public Safety to develop a strategy to identify, investigate, and track foreign influence operations. This bill provides for developing and sharing information about hostile foreign organizations that operate within Texas.

In addition, this bill creates a training program under the Texas Ethics Commission on foreign influence operations within Texas. This bill prohibits any employee or volunteer of a state agency or political subdivision from accepting gifts and travel from a foreign adversary, and creates reporting requirements for interactions with people representing foreign adversaries.

As proposed, S.B. 2514 amends current law relating to establishing the hostile foreign organizations unit at the Department of Public Safety and training, prohibitions, reporting requirements, and community outreach designed to combat foreign influence and creates a criminal offense.

RULEMAKING AUTHORITY

This bill does not expressly grant any additional rulemaking authority to a state officer, institution, or agency.

SECTION BY SECTION ANALYSIS

SECTION 1. Amends Section 411.002(a), Government Code, to provide that the Department of Public Safety of the State of Texas (DPS) is composed of certain divisions, including the hostile foreign organizations unit (unit).

SECTION 2. Amends Chapter 411, Government Code, by adding Subchapter S, as follows:

SUBCHAPTER S. HOSTILE FOREIGN ORGANIZATIONS UNIT

Sec. 411.551. DEFINITIONS. Defines "foreign influence operation" and "unit."

Sec. 411.552. HOSTILE FOREIGN ORGANIZATIONS UNIT. Provides that the unit is established in DPS to develop and make recommendations for implementing a strategy to identify, investigate, and track foreign influence operations in this state.

Sec. 411.553. UNIT CHIEF AND OTHER EMPLOYEES; ADDITIONAL DUTIES. Authorizes the public safety director (director) to appoint a unit chief and other unit employees as necessary to perform unit functions and assign to the unit and the unit chief any duties of another DPS division that relate to the investigation and tracking of hostile foreign organizations.

Sec. 411.554. STRATEGY DEVELOPMENT. Requires the unit, in collaboration with federal, state, and local agencies and private entities, to develop a strategy for identifying, investigating, and tracking:

(1) foreign influence operations in this state;

(2) individuals conducting foreign influence operations in this state; and

(3) any person who is an officer or employee of or is otherwise associated with a hostile foreign government or other hostile foreign organization and maintains regular contact with an individual described by Subdivision (2).

Sec. 411.555. RECOMMENDATIONS FOR IMPLEMENTING STRATEGY. Requires the unit to develop and report to the director recommendations for cyber intelligence services and other similar services necessary to implement the strategy developed under Section 411.554.

Sec. 411.556. SECURE STORAGE OF SENSITIVE INFORMATION. (a) Requires the unit to provide for the secure storage of sensitive information obtained or produced as part of the strategy developed under Section 411.554.

(b) Provides that information determined as sensitive under Subsection (a) is not subject to disclosure under Chapter 552 (Public Information).

Sec. 411.557. INFORMATION SHARING. Authorizes the unit, with the approval of the director, to share information determined sensitive under Section 411.556(a) with another federal, state, or local law enforcement agency. Provides that the disclosure of information under this section is not a voluntary disclosure under Section 552.007 (Voluntary Disclosure of Certain Information When Disclosure Not Required).

SECTION 3. Amends Chapter 470, Government Code, by adding Section 470.010, as follows:

[Note: S.B. 2514 as drafted does not contain any text in this space.]

SECTION 4. Amends Section 571.071, Government Code, by amending Subsection (a) and adding Subsections (e) and (f), as follows:

(a) Requires the Texas Ethics Commission (TEC) to perform certain actions, including providing, in cooperation with state agencies, a program of training for state employees on foreign influence in accordance with Subsection (e). Makes nonsubstantive changes.

(e) Requires TEC to develop a training program to educate state employees on the influence operations of foreign adversaries and other hostile foreign actors, including the United Front Work Department of the central committee of the Chinese Communist Party and other coordinated foreign influence operations. Requires that the training program include education on:

(1) known efforts by foreign adversaries to target and influence subnational governments, including efforts made by the United Front Work Department;

(2) identifying and recognizing suspected foreign influence operations;

(3) informational resources promulgated by federal, state, and nongovernmental organizations on United Front Work Department activities in this state and adjacent states; and

(4) reporting to TEC and law enforcement agencies suspected foreign influence operations and other interactions with persons acting on behalf of a foreign adversary.

(f) Defines "foreign adversary" and "foreign influence operation."

SECTION 5. Amends Subchapter C, Chapter 572, Government Code, by adding Section 572.070, as follows:

Sec. 572.070. PROHIBITIONS AND REPORTING REQUIREMENTS RELATED TO FOREIGN INFLUENCE; CRIMINAL OFFENSE. (a) Defines "foreign adversary."

(b) Prohibits an employee or volunteer of a state agency or a political subdivision of this state from accepting transportation to or lodging in a country that is a foreign adversary and that is paid for by the foreign adversary because of the employee's or volunteer's position with the state or political subdivision or accepting a gift or item of value from a person representing a foreign adversary for any purpose, including to pay for travel expenses or as reimbursement for the costs of attending a conference or other event in a country that is a foreign adversary or that is hosted on behalf of a foreign adversary or a principal of a foreign adversary.

(c) Requires an employee or volunteer of a state agency or a political subdivision of this state to report to TEC, in the form and manner TEC requires, each interaction, communication, or meeting the employee or volunteer has with a person acting on behalf of a foreign adversary not later than the 30th day after the date of the interaction, communication, or meeting. Requires TEC to make available a report under this subsection to the attorney general and DPS on request.

(d) Provides that a person commits an offense if the person violates this section. Provides that an offense under this subsection is a Class A misdemeanor.

SECTION 6. Requires the governor, as soon as practicable after the effective date of this Act but not later than January 1, 2026, to appoint the liaison required by Section 470.010, Government Code, as added by this Act.

SECTION 7. Makes application of Section 572.070(c), Government Code, as added by this Act, prospective to March 1, 2025.

SECTION 8. Effective date: September 1, 2025.

Senate Authors

Sen. Bryan HughesRepublican · Primary Author

Coauthors (2)

House Sponsor

Rep. Cole HefnerRepublican · Primary Sponsor

Bill Text(with markup)

S.B. No. 2514

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

	AN ACT
	relating to establishing the hostile foreign adversaries unit at
	the Department of Public Safety and training, prohibitions, and
	reporting requirements designed to combat foreign influence and
	foreign adversary operations; creating a criminal offense.
	BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF TEXAS:
	SECTION 1. Chapter 411, Government Code, is amended by
	adding Subchapter S to read as follows:
	SUBCHAPTER S. HOSTILE FOREIGN ADVERSARIES UNIT
	Sec. 411.551. DEFINITIONS. In this subchapter:
	(1) "Foreign adversary operation" means actions by
	adversarial foreign governments that threaten the safety and
	security of this state.
	(2) "Unit" means the department's hostile foreign
	adversaries unit established under this subchapter.
	Sec. 411.552. HOSTILE FOREIGN ADVERSARIES UNIT. The
	hostile foreign adversaries unit is established in the department
	to support the department's duty to prevent the harassment and
	coercion of this state's residents from foreign adversary
	operations, strengthen state agencies against foreign adversary
	operations, and protect this state's critical infrastructure
	against threats foreign adversary operations pose.
	Sec. 411.553. UNIT EMPLOYEES. The director may appoint
	unit employees as necessary to perform unit functions.
	Sec. 411.554. BIENNIAL REPORT. (a) Not later than December
	1 of each even-numbered year, the unit shall submit to the governor
	and the legislature a written report that assesses the threat
	foreign adversary operations posed to this state, including to this
	state's residents and governmental units, during the preceding two
	years. The report must include:
	(1) an assessment of the incidence of foreign
	adversary operations conducted in this state, including operations
	intended to influence political sentiment or public discourse; and
	(2) strategies that have proven effective to combat
	the operations described by Subdivision (1).
	(b) On request by the unit, a state agency or a local law
	enforcement agency shall provide to the unit information relating
	to any foreign adversary operation that the agency has researched
	or investigated or otherwise holds relevant information on.
	Sec. 411.555. ADDITIONAL DUTIES. (a) The unit shall
	collaborate with local governments and federal agencies to operate
	the Texas Fusion Center.
	(b) The unit shall refer for prosecution to the appropriate
	prosecuting attorney cases in which individuals or organizations
	have engaged in or assisted in foreign adversary operations in this
	state.
	Sec. 411.556. SECURE STORAGE OF SENSITIVE INFORMATION. (a)
	The unit shall provide for the secure storage of sensitive
	information obtained or produced as part of the report developed
	under Section 411.554.
	(b) Information determined as sensitive under Subsection
	(a) is not subject to disclosure under Chapter 552.
	Sec. 411.557. INFORMATION SHARING. With the approval of
	the director, the unit may share information determined sensitive
	under Section 411.556(a) with another federal, state, or local law
	enforcement agency. The disclosure of information under this
	section is not a voluntary disclosure under Section 552.007.
	Sec. 411.558. RULES. The commission may adopt rules to
	implement this subchapter.
	SECTION 2. Subchapter C, Chapter 572, Government Code, is
	amended by adding Section 572.070 to read as follows:
	Sec. 572.070. PROHIBITIONS AND REPORTING REQUIREMENTS
	RELATED TO FOREIGN INFLUENCE; CRIMINAL OFFENSE. (a) In this
	section, "foreign adversary" means a country:
	(1) identified by the United States Director of
	National Intelligence as a country that poses a risk to the national
	security of the United States in at least one of the three most
	recent Annual Threat Assessments of the U.S. Intelligence Community
	issued pursuant to Section 108B, National Security Act of 1947 (50
	U.S.C. Section 3043b); or
	(2) designated by the governor after consultation with
	the public safety director of the Department of Public Safety.
	(b) An employee or volunteer of a state agency or a
	political subdivision of this state may not:
	(1) accept transportation to or lodging in a country
	that is a foreign adversary and that is paid for by the foreign
	adversary because of the employee's or volunteer's position with
	the state or political subdivision; or
	(2) accept a gift or item of value from a person
	representing a foreign adversary for any purpose, including to pay
	for travel expenses or as reimbursement for the costs of attending a
	conference or other event in a country that is a foreign adversary
	or that is hosted on behalf of a foreign adversary or a principal of
	a foreign adversary.
	(c) An employee or volunteer of a state agency or a
	political subdivision of this state shall report to the commission,
	in the form and manner the commission requires, each interaction,
	communication, or meeting the employee or volunteer has with a
	person acting on behalf of a foreign adversary not later than the
	30th day after the date of the interaction, communication, or
	meeting. The commission shall make available a report under this
	subsection to the attorney general and the Texas Department of
	Public Safety on request.
	(d) A person commits an offense if the person knowingly
	violates this section. An offense under this subsection is a state
	jail felony.
	SECTION 3. Section 2054.519, Government Code, is amended by
	adding Subsections (f) and (g) to read as follows:
	(f) In addition to the requirements for certification under
	Subsection (b), a cybersecurity training program must include
	education on:
	(1) the threat of foreign adversaries and other
	hostile foreign actors, including the United Front Work Department
	of the Central Committee of the Chinese Communist Party and other
	coordinated foreign influence operations;
	(2) known efforts by foreign adversaries to target and
	influence subnational governments, including efforts made by the
	United Front Work Department;
	(3) identifying and recognizing suspected foreign
	influence operations;
	(4) informational resources promulgated by federal,
	state, and nongovernmental organizations on United Front Work
	Department activities in this state and adjacent states; and
	(5) reporting to the Texas Ethics Commission as
	required by Section 572.070 and to law enforcement agencies
	suspected foreign influence operations and other interactions with
	persons acting on behalf of a foreign adversary.
	(g) In Subsection (f), "foreign adversary" has the meaning
	assigned by Section 572.070.
	SECTION 4. Section 572.070(c), Government Code, as added by
	this Act, applies to an interaction, communication, or meeting with
	a person acting on behalf of a foreign adversary that occurs on or
	after March 1, 2025. A person required to report an interaction,
	communication, or meeting under that section that occurred before
	the effective date of this Act shall make the report not later than
	the 30th day after the effective date of this Act.
	SECTION 5. (a) Not later than December 1, 2025, the
	Department of Information Resources shall adopt rules implementing
	the certification requirements of Section 2054.519(f), Government
	Code, as added by this Act.
	(b) Section 2054.519(f), Government Code, as added by this
	Act, applies only to the certification of a cybersecurity training
	program under that section that occurs on or after May 1, 2026. The
	certification of a cybersecurity training program under that
	section that occurs before May 1, 2026, is governed by the law in
	effect on the date of the certification, and the former law is
	continued in effect for that purpose.
	SECTION 6. This Act takes effect September 1, 2025.

LEGISLATIVE BUDGET BOARD
Austin, Texas

FISCAL NOTE, 89TH LEGISLATIVE REGULAR SESSION


April 14, 2025

TO:	Honorable Bryan Hughes, Chair, Senate Committee on State Affairs

FROM:	Jerry McGinty, Director, Legislative Budget Board

IN RE:	SB2514 by Hughes (Relating to establishing the hostile foreign organizations unit at the Department of Public Safety and training, prohibitions, reporting requirements, and community outreach designed to combat foreign influence; creating a criminal offense.), As Introduced

Estimated Two-year Net Impact to General Revenue Related Funds for SB2514, As Introduced: a negative impact of ($11,066,853) through the biennium ending August 31, 2027.

The bill would make no appropriation but could provide the legal basis for an appropriation of funds to implement the provisions of the bill.

General Revenue-Related Funds, Five- Year Impact:

Fiscal Year	Probable Net Positive/(Negative) Impact to General Revenue Related Funds
2026	($6,885,676)
2027	($4,181,177)
2028	($4,181,177)
2029	($4,181,177)
2030	($4,181,177)

All Funds, Five-Year Impact:

Fiscal Year	Probable Savings/(Cost) from General Revenue Fund 1	Change in Number of State Employees from FY 2025
2026	($6,885,676)	19.0
2027	($4,181,177)	19.0
2028	($4,181,177)	19.0
2029	($4,181,177)	19.0
2030	($4,181,177)	19.0

Fiscal Analysis

The bill would establish the Hostile Foreign Organization Unit within the Department of Public Safety (DPS) and direct DPS to create certain recommendations related to identifying, investigating, and monitoring certain foreign government activities and establishing collaboration with certain entities. The bill would also direct the Texas Ethics Commission to develop a training related to hostile foreign actors and establish certain reporting requirements. Under the provisions of the bill, it would be an offense to violate certain provisions.

Methodology

According to DPS, the duties and responsibilities associated with implementing the provisions of the bill could not be absorbed within existing resources. DPS states that 15.0 full-time equivalent positions (FTEs) would be needed to staff the unit including 1.0 Captain, 1.0 Major, 9.0 Sergeants, 1.0 Lieutenant, 1.0 Administrative Assistant III, 1.0 Director VII, and 1.0 Deputy Director II. The agency would also need 4.0 FTEs to indirect support the operations of the unit including 1.0 Criminal Intelligence Analyst III, 1.0 Forensic Specialist, 1.0 Police Communications Operator, and 1.0 Program Specialist V.

This analysis includes $3,402,555 in fiscal year 2026 and $3,402,555 in fiscal year 2027 for salary and benefits. Other costs including consumables supplies, travel, fuel, rent, other operating expenses, and capital expenditures would total $3,483,121 in fiscal year 2026 and $778,622 in fiscal year 2027

It is assumed that any fiscal impact and any impact on state correctional populations or on the demand for state correctional resources resulting from the new offense would not be significant.

Local Government Impact

It is assumed that any fiscal impact to units of local government resulting from the new offense and associated with enforcement, prosecution, supervision, or confinement would not be significant.

Source Agencies:

356 Texas Ethics Commission, 405 Department of Public Safety

LBB Staff:

JMc, WP, CSh, KVEL, CMA

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Frequently Asked Questions

Common questions about SB2514

What does Texas SB2514 do?

SB2514 criminalizes unreported interactions with "foreign adversaries" for public officials, effectively forcing private sector vendors and lobbyists to certify their foreign ties to avoid implicating government clients in a State Jail Felony. The law imposes a retroactive reporting requirement starting March 1, 2025, creating immediate liability risks for any business interacting with Texas state or local agencies that has ties to China, Russia, Iran, or North Korea. Implementation Timeline Effective Date: September 1, 2025 Compliance Deadline: March 1, 2025 (Operational "Go-Live").

Who authored SB2514?

SB2514 was authored by Texas Senator Bryan Hughes during the Regular Session.

When was SB2514 signed into law?

SB2514 was signed into law by Governor Greg Abbott on June 20, 2025.

Which agencies enforce SB2514?

SB2514 is enforced by Department of Public Safety (Hostile Foreign Adversaries Unit), Texas Ethics Commission, Attorney General and Local Prosecuting Attorneys.

How urgent is compliance with SB2514?

The compliance urgency for SB2514 is rated as "critical". Businesses and organizations should review the requirements and timeline to ensure timely compliance.

What is the cost impact of SB2514?

The cost impact of SB2514 is estimated as "medium". This may vary based on industry and implementation requirements.

What topics does SB2514 address?

SB2514 addresses topics including crimes, crimes--miscellaneous, governor, intergovernmental relations and law enforcement.

Legislative data provided by LegiScanLast updated: November 25, 2025

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