Relating to a permit issued by the Parks and Wildlife Department for certain hunting dog field trials; authorizing a fee.
ModeratePlan for compliance
Low Cost
Effective:2025-09-01
Enforcing Agencies
Texas Parks and Wildlife Department
01
Compliance Analysis
Key implementation requirements and action items for compliance with this legislation
Implementation Timeline
Effective Date: September 1, 2025.
Compliance Deadline:Post-Rulemaking. While the law is effective in September, you cannot utilize the license exemption until the Texas Parks and Wildlife Department (TPWD) finalizes the application forms and issuance system.
Agency Rulemaking: The TPWD Commission is statutorily required to adopt rules "as soon as practicable" after September 1, 2025.
*Regulatory Gray Zone:* Between Sept 1, 2025, and the final adoption of rules, the permit will not exist. During this interim, you must continue to enforce individual hunting license requirements for all participants.
Immediate Action Plan
1.Audit Upcoming Schedule: Identify all events scheduled after September 1, 2025, involving squirrels, raccoons, or non-game species.
2.Update Waivers: Redraft liability releases to align with the limited scope of the SB2801 exemption.
3.Monitor Commission Agenda: Assign counsel to monitor TPWD Commission meetings in Q3 2025 for the publication of the proposed application form.
4.Prepare Data Sets: Consolidate property legal descriptions and landowner consent forms now to ensure rapid application submission once the portal opens.
Operational Changes Required
Contracts
Land Lease Agreements: Landowners must amend leases to require the Lessee (Organizer) to provide proof of the SB2801 permit 48 hours prior to the event start.
Liability Waivers: Update participant waivers to explicitly state that the hunting license exemption is valid only on the permitted property and only during the nine-day window. Participants traveling outside these bounds remain personally liable for poaching violations.
Vendor Agreements: Define responsibility for permit application filing if utilizing third-party event secretaries.
Hiring/Training
Field Staff: Event staff must be trained to maintain a real-time "Master List" of participants. This list must be producible immediately upon a Game Warden's request to validate the license exemption.
Compliance Officer: Designate one individual responsible for tracking the 9-day permit window. If an event extends to a 10th day, a second permit application and fee are mandatory.
Reporting & Record-Keeping
Pre-Event: Submission of TPWD application detailing property location, target species (squirrel, fur-bearing, or non-game), and sanctioning club.
On-Site: The physical or digital permit must be displayed or held by the event master.
Audit Trail: Maintain the roster of "registered participants" for at least 12 months post-event to defend against potential retroactive citations.
Fees & Costs
Permit Fee:$50.00 per event (valid for up to 9 consecutive days).
Cost Offset: This fee effectively replaces the need for out-of-state participants to purchase Non-Resident Special Hunting Licenses ($48-$132), offering a significant marketing tool for event organizers.
Strategic Ambiguities & Considerations
The statute leaves critical operational details to TPWD discretion. Watch the Texas Register for the following definitions:
1."Participant" Definition: It is currently unclear if the license exemption extends to judges, scouts, and gallery members, or applies strictly to dog handlers. Narrow rulemaking could leave support staff exposed to citations.
2.Application Lead Time: The statute does not set a submission deadline. If TPWD rules require 30+ days' notice for approval, "pop-up" or short-notice trials will be operationally impossible to permit.
3.Authorized Public Lands: The bill allows trials on public land *only* if authorized by the Commission. Do not assume local Wildlife Management Areas (WMAs) are automatically approved until the specific list is published.
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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.
Under current law, a Texas hunting license is required per individual during certain competitive field trial events where individuals and their dogs track, locate, and tree squirrels, nongame, and fur-bearing animals. Other states have created event permits that waive the hunting license requirement when weapons are not carried, and animals are not taken or harvested.
Under current law, Texas allows this type of permit to be acquired for sanctioned field trial events for banded pen-reared birds.
S.B. 2801 expands the use of this permit to sanctioned field trial events for squirrels, nongame, and fur-bearing animals. This bill allows one $50 permit to be acquired per event to waive the requirement for every individual on the premises to hold a hunting license ($7 - $315 per person, depending on age and residency), saving participants time and money while providing notice to the agency and neighboring landowners that an event will take place at a time certain.
This permit is not a requirement for these types of events to be held. If Texans prefer to operate under the current process, they may continue to individually purchase a Texas hunting license and not pursue a field trial event permit.
As proposed, S.B. 2801 amends current law relating to a permit issued by the Parks and Wildlife Department for certain hunting dog field trials and authorizes a fee.
RULEMAKING AUTHORITY
Rulemaking authority is expressly granted to the Texas Parks and Wildlife Commission in SECTION 1 (Section 43.253, Parks and Wildlife Code) of this bill.
SECTION BY SECTION ANALYSIS
SECTION 1. Amends Chapter 43, Parks and Wildlife Code, by adding Subchapter J, as follows:
SUBCHAPTER J. FIELD TRIAL PERMIT
Sec. 43.251. DEFINITIONS. Defines "field trial," "field trial permit," "fur-bearing animal," "nongame," and "squirrel."
Sec. 43.252. FIELD TRIAL PERMIT. (a) Authorizes a person to apply to the Texas Parks and Wildlife Department (TPWD) in the manner prescribed by Texas Parks and Wildlife Commission (TPWC) rules for a permit under this section exempting registered participants in a field trial held by the person from the hunting license requirements of Chapter 42 (General Hunting License) while the individuals are participating in the field trial.
(b) Authorizes TPWD to issue a permit under this section only for a field trial held on privately owned land or on public land authorized under TPWC rules adopted under Section 43.253(a).
(c) Requires that an application for a field trial permit meet certain criteria.
(d) Provides that the fee for a field trial permit is $50.
(e) Provides that a field trial permit is valid for a period of nine consecutive days and only on the land specified in the permit.
Sec. 43.253. COMMISSION RULES. (a) Requires TPWC to adopt rules specifying the public lands for which a field trial permit is authorized to be issued.
(b) Authorizes TPWC to adopt rules as necessary to administer this subchapter, including rules necessary to manage and protect wildlife subject to a field trial permit.
Sec. 43.254. HUNTING LICENSE NOT REQUIRED DURING FIELD TRIAL. Provides that an individual registered to participate in a field trial held under a field trial permit is exempt from the hunting license requirements of Chapter 42 while the individual is participating in the field trial.
SECTION 2. Requires TPWC, as soon as practicable after the effective date of this Act, to adopt rules necessary to implement Subchapter J, Chapter 43 (Special Licenses and Permits), Parks and Wildlife Code, as added by this Act.
SECTION 3. Effective date: upon passage or September 1, 2025.
Honorable Charles Perry, Chair, Senate Committee on Water, Agriculture and Rural Affairs
FROM:
Jerry McGinty, Director, Legislative Budget Board
IN RE:
SB2801 by Hughes (Relating to a permit issued by the Parks and Wildlife Department for certain hunting dog field trials; authorizing a fee.), As Introduced
The fiscal implications of the bill cannot be determined because the number of newly created field trial permits that would be issued and the number of hunting licenses currently issued under Parks and Wildlife Code Chapter 42 that would no longer be issued is unknown.
This bill would make no appropriation but could provide the legal basis for an appropriation of funds to implement the provisions of the bill.
The bill would amend the Parks and Wildlife code to allow a person to apply to the Texas Parks and Wildlife Department (TPWD) for a Field Trial Permit with a $50 fee that would authorize participants in the field trial event to use dogs to hunt for non-game animals such as squirrels or other fur-bearing animals. The permit would be valid for nine consecutive days on private property or certain public land authorized by the Texas Parks and Wildlife Commission (Commission) that would be specified in the permit. The bill would exempt participants under the Field Trial Permit from the hunting license requirement established in Parks and Wildlife Code Chapter 42.
The bill would require the Commission to adopt rules necessary to implement the provisions of the bill. The bill would take effect immediately upon receiving a two-thirds majority votes in both houses; otherwise, it would take effect September 1, 2025.
Based on analysis by the Comptroller of Public Accounts and TPWD, the revenue implications of the bill cannot be determined because the number of newly created field trial permits that would be issued and the number of hunting licenses currently issued under Parks and Wildlife Code Chapter 42 that would no longer be issued is unknown.
Based on information provided by TPWD, it is assumed that administrative costs as well as costs for programming changes to the hunting/fishing license system and transactions processed through it related to third party vendor involvement could be absorbed using existing resources.
Note: This legislation would do one or more of the following: create or recreate a dedicated account in the General Revenue Fund, create or recreate a special or trust fund either in, with, or outside the Treasury, or create a dedicated revenue source. The fund, account, or revenue dedication included in this bill would be subject to funds consolidation review by the current Legislature.
Local Government Impact
No fiscal implication to units of local government is anticipated.
Source Agencies:
304 Comptroller of Public Accounts, 802 Parks and Wildlife Department
LBB Staff:
JMc, FV, MW, RSTE
Related Legislation
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SB2801 fundamentally shifts regulatory liability for hunting dog field trials from individual participants to the event organizer. Effective September 1, 2025, organizers may purchase a $50 Field Trial Permit that exempts all registered participants from holding individual Texas hunting licenses for the duration of the event. This creates a competitive advantage for organizers but requires strict adherence to new centralized permitting and roster maintenance protocols.
Q
Who authored SB2801?
SB2801 was authored by Texas Senator Bryan Hughes during the Regular Session.
Q
When was SB2801 signed into law?
SB2801 was signed into law by Governor Greg Abbott on June 20, 2025.
Q
Which agencies enforce SB2801?
SB2801 is enforced by Texas Parks and Wildlife Department.
Q
How urgent is compliance with SB2801?
The compliance urgency for SB2801 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of SB2801?
The cost impact of SB2801 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does SB2801 address?
SB2801 addresses topics including animals, parks & wildlife, parks & wildlife--general, parks & wildlife--hunting & fishing and parks & wildlife--licenses.
Legislative data provided by LegiScanLast updated: November 25, 2025
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