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Signed Into Law
Signed June 20, 2025Effective 2025-09-01
SB2580

Regular Session

Relating to the definition of a designated law enforcement office or agency for purposes of certain laws governing the installation and use of tracking equipment and access to certain communications.

Government Affairs & Regulatory Compliance Analysis

SB2580: Government Affairs Overview

SB2580 significantly expands the list of law enforcement agencies authorized to issue tracking and interception orders (pen registers/trap and trace) by lowering the population threshold for Sheriff’s Departments from 3. 3 million to 500,000. Telecommunications carriers, ISPs, and digital platforms must immediately update their legal compliance verification protocols to accept orders from these newly authorized counties while continuing to reject requests from smaller jurisdictions to avoid wrongful disclosure liability.

Sen. Kelly Hancock·Senate Bill·Regular Session

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

Sheriff's departments in counties with a population of 500,000 or more (Expansion of authority)

Business Impact

Who SB2580 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.

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Technology

Affected business types:

  • Data centers
  • Technology companies
  • Software developers
  • Telecommunications providers
View all technology legislation

Key Operational Considerations

  • 1Intake Staff Training: Law Enforcement Response Teams (LERT) must be retrained. Staff can no longer assume only major metro PDs or the Harris County Sheriff have this authority.
  • 2Validation Protocols: Staff must be trained to verify the *requesting agency's jurisdiction population*, not just the judge's signature.

Estimated Cost Impact

lowMinimal cost impact anticipated.

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SB2580
Moderate
Relating to the definition of a designated law enforcement office or agency for purposes of certain laws governing the installation and use of trackin...
Moderate Compliance Urgency
Requires near-term attention
Cost Impact
Low
Effective
2025-09-01
Enforcing Agencies
Sheriff's departments in countie...
Primary Author: Sen. Kelly Hancock
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 (Your intake teams must be ready to validate orders from the expanded list on this date).
  • Agency Rulemaking: None. This is a statutory definition change; no regulatory agency will issue further guidance.

Immediate Action Plan

  • 1. Audit Jurisdiction List: Immediately map Texas counties by population using 2020 Census data to identify the newly qualifying jurisdictions (500k+).
  • 2. Update Software Logic: Reconfigure intake portals to flag Sheriff's Department requests from the newly qualifying counties as "Valid" starting September 1.
  • 3. Notify Vendors: Send formal notice to outside counsel or compliance vendors regarding the statutory change.
  • 4. Brief LERT Managers: Ensure managers understand that rejecting a valid order from a newly authorized Sheriff (e.g., Denton County) after Sept 1 could result in immediate contempt of court proceedings.

Operational Changes Required

Contracts

  • Third-Party Compliance Vendors: If you outsource subpoena/warrant response (e.g., to a dedicated LERT vendor), you must issue a directive requiring them to update their "authorized agency" logic by September 1. You remain liable for their rejection of valid orders or acceptance of invalid ones.
  • Privacy Policies: Review "Disclosure to Law Enforcement" clauses. Ensure internal definitions of "valid legal process" align with this statutory expansion to prevent breach of contract claims from users.

Hiring/Training

  • Intake Staff Training: Law Enforcement Response Teams (LERT) must be retrained. Staff can no longer assume only major metro PDs or the Harris County Sheriff have this authority.
  • Validation Protocols: Staff must be trained to verify the *requesting agency's jurisdiction population*, not just the judge's signature.

Reporting & Record-Keeping

  • "White List" Expansion: Update your internal database of authorized requestors. You must add Sheriff’s Departments for counties including Dallas, Tarrant, Bexar, Travis, Collin, Denton, Hidalgo, El Paso, Fort Bend, Montgomery, and Williamson.
  • Rejection Logging: Maintain a specific log for requests rejected because the Sheriff's county population is *under* 500,000. This is your primary defense against contempt of court allegations.

Fees & Costs

  • Cost Impact: Low.
  • Reimbursement: Standard reimbursement rates for assembling and providing data under the Code of Criminal Procedure still apply; this bill does not alter fee schedules, only the volume of potential requests.

Strategic Ambiguities & Considerations

  • Population Data Source: The statute specifies "population of 500,000 or more" but does not define the controlling data source (e.g., 2020 Decennial Census vs. current Annual Estimates).
  • *Risk:* "Bubble" counties (e.g., those with 490k in 2020 but 510k in 2024).
  • *Guidance:* Adhere to the 2020 Decennial Census as the strict legal standard until the Attorney General issues an opinion allowing the use of estimates. Accepting an order based on estimates carries a risk of wrongful disclosure liability.
  • Task Forces: A Sheriff from a small (unauthorized) county may attempt to issue an order while participating in a task force hosted by a large (authorized) county.
  • *Guidance:* The *signatory agency* on the application controls. If the applicant is the Sheriff of a small county, the request is invalid, regardless of task force affiliation.

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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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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 13, 2025
Passed Senate
May 1, 2025
Passed House
May 23, 2025
Signed
Jun 20, 2025
Effective
Sep 1, 2025
TopicsCounty GovernmentCounty Government--employees/officersCrime PreventionLaw EnforcementSafetyUtilitiesUtilities--telecommunicationsSheriffs
03

Senate Authors

Sen. Kelly HancockRepublican · Primary Author

House Sponsors

Rep. Nate SchatzlineRepublican · Primary Sponsor
Joint Sponsors

Bill Text(with markup)

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

Related Legislation

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More from Sen. Kelly Hancock

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Related by Topic

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Quick Reference

Frequently Asked Questions

Common questions about SB2580

Q

What does Texas SB2580 do?

SB2580 significantly expands the list of law enforcement agencies authorized to issue tracking and interception orders (pen registers/trap and trace) by lowering the population threshold for Sheriff’s Departments from 3. 3 million to 500,000. Telecommunications carriers, ISPs, and digital platforms must immediately update their legal compliance verification protocols to accept orders from these newly authorized counties while continuing to reject requests from smaller jurisdictions to avoid wrongful disclosure liability.

Q

Who authored SB2580?

SB2580 was authored by Texas Senator Kelly Hancock during the Regular Session.

Q

When was SB2580 signed into law?

SB2580 was signed into law by Governor Greg Abbott on June 20, 2025.

Q

Which agencies enforce SB2580?

SB2580 is enforced by Sheriff's departments in counties with a population of 500,000 or more (Expansion of authority).

Q

How significant are the changes in SB2580?

The regulatory priority for SB2580 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of SB2580?

The cost impact of SB2580 is estimated as "low". This may vary based on industry and implementation requirements.

Q

What topics does SB2580 address?

SB2580 addresses topics including county government, county government--employees/officers, crime prevention, law enforcement and safety.

Q

What are the key dates for SB2580?

Key dates for SB2580: Effective date is 2025-09-01. Consult with legal counsel regarding applicability.

Q

Which Texas businesses are affected by SB2580?

SB2580 primarily affects utility companies and energy providers, telecommunications providers. 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