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Signed Into Law
Signed May 20, 2025Effective 2025-09-01
SB494

Regular Session

Relating to the establishment of a theft of petroleum products task force.

Government Affairs & Regulatory Compliance Analysis

SB494: Government Affairs Overview

SB 494 establishes the "Theft of Petroleum Products Task Force" under the Railroad Commission of Texas (RRC), creating the regulatory architecture that will define future security and reporting standards for the oil and gas industry through 2030. While immediate operational changes are not mandated, this Act signals imminent scrutiny on chain-of-custody protocols; upstream, midstream, and transport operators must engage immediately to ensure industry representation shapes the Task Force's recommendations for the 2027 legislative session.

Sen. Kevin Sparks·Senate Bill·Regular Session

Low
Low Cost
Effective:2025-09-01

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SB494
Low
Relating to the establishment of a theft of petroleum products task force.
Low Compliance Urgency
Requires routine attention
Cost Impact
Low
Effective
2025-09-01
Enforcing Agencies
Railroad Commission of Texas
Primary Author: Sen. Kevin Sparks
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: Strategic Deadline Only. There are no immediate operational deadlines. However, industry nominations for Task Force membership must be prepared prior to September 1, 2025, to ensure appointment "as soon as practicable" thereafter.
  • Agency Rulemaking: The RRC is not required to issue industry rules immediately. Instead, they must appoint the Task Force members shortly after September 1, 2025. The Task Force's first mandatory report (due December 1, 2026) will likely trigger the actual rulemaking and legislative mandates for the 2027 session.

Immediate Action Plan

  • 1. Nominate Representatives: Contact our Government Affairs team immediately to submit qualified candidates for the "energy trade association" seat on the Task Force.
  • 2. Audit Loss Data: Conduct an internal review of petroleum loss/theft rates over the last 24 months to identify vulnerabilities and prepare anonymized data for industry advocacy.
  • 3. Review Insurance: Consult with your broker to determine if your current theft coverage is contingent on specific security measures, and monitor how Task Force findings might impact premiums.
  • 4. Monitor Appointments: Track RRC announcements in Q4 2025 to verify the composition of the Task Force is balanced and knowledgeable.

Operational Changes Required

Contracts

  • Security Vendor Agreements: Review current contracts with site security and monitoring providers. Ensure terms allow for flexibility to upgrade technology (e.g., digital ticketing, flow monitoring) without excessive penalties, as the Task Force may recommend specific technological standards by 2027.
  • Transport MSAs: No immediate amendment required. However, prepare to revise Master Service Agreements to clarify liability for product "shrinkage" or theft in transit, as the Task Force is mandated to study sales tax impacts of theft.

Hiring/Training

  • No immediate hiring requirements.
  • Internal Audit: Designate a current compliance officer or operations manager to aggregate internal data regarding product loss and theft incidents. This data will be essential to defend against onerous regulations during the Task Force's fact-finding phase.

Reporting & Record-Keeping

  • No new statutory forms.
  • Data Preparation: The Task Force will request data on "issues relating to the theft of petroleum products." Ensure your internal incident reports and loss logs are accurate and privileged where possible, anticipating RRC or Task Force inquiries.

Fees & Costs

  • No new fees. The Legislative Budget Board anticipates no significant fiscal implication to the State, meaning the RRC will absorb administrative costs.
  • Future Cost Warning: Anticipate potential capital expenditures for enhanced metering or security fencing post-2026 if recommended by the Task Force.

Strategic Ambiguities & Considerations

  • Definition of "Transparency": The Act mandates recommendations to "increase transparency." This is undefined and dangerous. It could range from simple reporting to invasive, real-time government monitoring of flow data. We must define this term via our Task Force representatives before the RRC defines it for us.
  • "Effective Strategies": The Task Force is charged with determining effective strategies to combat theft. Once published in the 2026 report, these strategies may establish a de facto "industry standard of care." Failure to adopt them voluntarily could expose operators to negligence lawsuits before any law is even passed.
  • Consultation Scope: Subsection (g) allows the Task Force to consult with "any organization." This opens the door for non-industry groups to influence security mandates.

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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
Nov 22, 2024
Passed Senate
Mar 12, 2025
Passed House
May 1, 2025
Signed
May 20, 2025
Effective
Sep 1, 2025
TopicsCrimesCrimes--against PropertyInterim StudiesOil & GasRailroad CommissionState Agencies, Boards & CommissionsState Agencies, Boards & Commissions--newly Proposed
03

Senate Authors

Sen. Kevin SparksRepublican · Primary Author
Coauthors (5)

House Sponsors

Rep. Brooks LandgrafRepublican · 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 SB494

Q

What does Texas SB494 do?

SB 494 establishes the "Theft of Petroleum Products Task Force" under the Railroad Commission of Texas (RRC), creating the regulatory architecture that will define future security and reporting standards for the oil and gas industry through 2030. While immediate operational changes are not mandated, this Act signals imminent scrutiny on chain-of-custody protocols; upstream, midstream, and transport operators must engage immediately to ensure industry representation shapes the Task Force's recommendations for the 2027 legislative session.

Q

Who authored SB494?

SB494 was authored by Texas Senator Kevin Sparks during the Regular Session.

Q

When was SB494 signed into law?

SB494 was signed into law by Governor Greg Abbott on May 20, 2025.

Q

Which agencies enforce SB494?

SB494 is enforced by Railroad Commission of Texas.

Q

How significant are the changes in SB494?

The regulatory priority for SB494 is rated as "low". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of SB494?

The cost impact of SB494 is estimated as "low". This may vary based on industry and implementation requirements.

Q

What topics does SB494 address?

SB494 addresses topics including crimes, crimes--against property, interim studies, oil & gas and railroad commission.

Q

What are the key dates for SB494?

Key dates for SB494: Effective date is 2025-09-01. Rulemaking: Appoint members to the Theft of Petroleum Products Task Force, including industry and trade association representatives. (As soon as practicable after 2025-09-01). Consult with legal counsel regarding applicability.

Q

Which Texas businesses are affected by SB494?

SB494 primarily affects property owners and real estate professionals. 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