Regular Session
Government Affairs & Regulatory Compliance Analysis
SB266 fundamentally restructures Texas tax audit defense by allowing businesses to bypass the Comptroller’s administrative redetermination process and file suit directly in District Court for managed audits. Crucially, it removes the requirement that records be "contemporaneous," allowing retrospective documentation to substantiate claims, while simultaneously imposing a strict 10% penalty for failure to pay final judgments within 20 days.
Sen. Charles Perry·Senate Bill·Regular Session
Comptroller of Public Accounts • Office of the Attorney General (OAG)
This legislation has regulatory implications for the following Texas businesses and organizations:
Notable regulatory updates (effective 2025-09-01). Consider how these changes may affect your operations.
Affected business types:
lowMinimal cost impact anticipated.
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JD Key Consulting provides strategic guidance on Texas regulatory compliance and legislative impact for your business.
Key implementation requirements and action items for compliance with 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 ConsultationInformation 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.
This bill's path through the Texas Legislature
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Common questions about SB266
SB266 fundamentally restructures Texas tax audit defense by allowing businesses to bypass the Comptroller’s administrative redetermination process and file suit directly in District Court for managed audits. Crucially, it removes the requirement that records be "contemporaneous," allowing retrospective documentation to substantiate claims, while simultaneously imposing a strict 10% penalty for failure to pay final judgments within 20 days.
SB266 was authored by Texas Senator Charles Perry during the Regular Session.
SB266 was signed into law by Governor Greg Abbott on May 24, 2025.
SB266 is enforced by Comptroller of Public Accounts and Office of the Attorney General (OAG).
The regulatory priority for SB266 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of SB266 is estimated as "low". This may vary based on industry and implementation requirements.
SB266 addresses topics including taxation, taxation--general, audits & auditors, comptroller of public accounts and civil remedies & liabilities.
Key dates for SB266: Effective date is 2025-09-01. Consult with legal counsel regarding applicability.
SB266 establishes the following penalties: administrative penalty of 10% of amount due (exclusive of other penalties/interest) for Failure to pay the amount determined due in a final judgment within 20 days after the judgment becomes final (specifically following a suit where the initial determination penalty was abated).; civil penalty of Damages awarded under Chapter 65, Civil Practice and Remedies Code for If the court determines that enjoined collection amounts were disputed solely for the purpose of delay.. Consult with legal counsel for specific applicability to your situation.
SB266 primarily affects property owners and real estate professionals. These businesses should review the legislation with their legal and compliance teams to understand potential impacts.
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.
