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Signed Into Law
Signed June 20, 2025Effective 2025-09-01
SB75

Regular Session

Relating to the resilience of the electric grid and certain municipalities.

Government Affairs & Regulatory Compliance Analysis

SB75: Government Affairs Overview

SB75 imposes immediate operational mandates on all Electric Generation and Transmission/Distribution Service Providers (TDSPs) to conduct biennial "physical attack" simulations coordinated with law enforcement. While the newly formed Texas Grid Security Commission (TGSC) has until late 2026 to develop long-term infrastructure hardening standards, market participants must immediately update Emergency Action Plans and prepare for mandatory reporting to ERCOT to avoid PUC enforcement actions.

Sen. Bob Hall·Senate Bill·Regular Session

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

ERCOT • Public Utility Commission of Texas (PUC) • Texas Division of Emergency Management (TDEM) • Texas Grid Security Commission (TGSC)

Business Impact

Who SB75 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.

⚡

Energy

Affected business types:

  • Power generators
  • Electric utilities
  • Renewable energy developers
  • Battery storage operators
View all energy legislation

Key Operational Considerations

  • 1Fuel Supply: Review "Force Majeure" clauses in natural gas and fuel supply contracts. Determine if "All Hazards" (specifically EMP or cyber-induced physical damage) are covered events.

Estimated Cost Impact

mediumModerate costs expected for implementation.

Enforcing Agencies

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SB75
Moderate
Relating to the resilience of the electric grid and certain municipalities.
Moderate Compliance Urgency
Requires near-term attention
Cost Impact
Medium
Effective
2025-09-01
Enforcing Agencies
ERCOTPUCTDEMTGSC
Primary Author: Sen. Bob Hall
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: December 31, 2026 (Deadline for completing the first mandatory physical attack tabletop exercise and submitting the required attestation to ERCOT).
  • Agency Rulemaking: The TGSC must submit "All Hazards" resilience standards (EMP, cyber, physical) to the Legislature by December 1, 2026. Expect the PUC to initiate rulemaking in Q1 2027 to codify these recommendations into binding "Standard of Care" regulations.

Immediate Action Plan

  • 1. Update EAPs Immediately: Revise Emergency Action Plans to include specific protocols for physical sabotage and active shooter scenarios, distinct from weather events.
  • 2. Initiate Law Enforcement Outreach: Do not wait until 2026. Contact local and state law enforcement liaisons now to schedule the required tabletop exercises.
  • 3. Audit Insurance Policies: Review property and business interruption policies. Once TGSC standards are published in 2026, they will establish the industry "Standard of Care." Coverage may be denied for future losses if you are found non-compliant with these new standards.
  • 4. Segregate Critical Data: Establish protocols to ensure specific substation vulnerability data is used in exercises but *not* transmitted to ERCOT in the final report.

Operational Changes Required

Contracts

  • Security Vendor Agreements: Review Master Service Agreements (MSAs) with private security firms. Amend Scopes of Work to explicitly require their participation in biennial tabletop exercises at no additional cost.
  • Law Enforcement MOUs: Pursue formal Memorandums of Understanding with local Sheriff’s Offices or PDs. You need a contractual or written basis to prove you attempted coordination if they later fail to participate.
  • Fuel Supply: Review "Force Majeure" clauses in natural gas and fuel supply contracts. Determine if "All Hazards" (specifically EMP or cyber-induced physical damage) are covered events.

Hiring/Training

  • Mandatory Exercises: Operations teams must transition from standard load-shedding drills to "physical attack" simulations. These must be distinct events, not combined with weather preparedness drills.
  • Security Clearances: If your technical leadership is nominated to the TGSC or its working groups, they must be eligible for and obtain federal secret security clearances.

Reporting & Record-Keeping

  • ERCOT Attestation: You must file a written attestation to ERCOT after every biennial exercise confirming that law enforcement roles were identified. Failure to file triggers PUC administrative penalties.
  • Data Segregation: TDSPs must maintain internal records of exercise scenarios but are explicitly *not* required to disclose specific critical substation locations to ERCOT during these exercises. Ensure your internal compliance logs segregate this sensitive data.

Fees & Costs

  • Internal Costs: All costs for conducting exercises and coordinating with law enforcement are borne by the provider.
  • Penalty Exposure: Failure to submit the attestation or conduct the exercise subjects the entity to PUC administrative penalties of up to $25,000 per violation, per day (Util. Code 15.023).

Strategic Ambiguities & Considerations

  • The "Uncooperative Sheriff" Risk: The law mandates you coordinate with law enforcement, but does not statutorily compel local agencies to coordinate with *you*. If local agencies lack resources to participate, document every attempt in writing to build a defense against PUC enforcement.
  • Micro-grid Scope: The bill mandates resilience standards for micro-grids but fails to define a size threshold. Commercial entities with robust backup generation (hospitals, data centers) should monitor TGSC rulemaking to ensure they are not inadvertently regulated as utilities.
  • Future Retrofit Liability: The TGSC is studying EMP hardening (100 kV/m E1). If these standards are adopted in 2027, the law does not currently guarantee "grandfathering" for existing assets, creating a risk of massive capital expenditure requirements for transformers and SCADA systems.

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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.

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Legislative Timeline

This bill's path through the Texas Legislature

Filed
Nov 12, 2024
Passed Senate
Apr 16, 2025
Passed House
May 21, 2025
Signed
Jun 20, 2025
Effective
Sep 1, 2025
TopicsDisaster Preparedness & ReliefEnergyEnergy--generalSafetyState Agencies, Boards & CommissionsState Agencies, Boards & Commissions--newly ProposedUtilitiesUtilities--electricElectric Reliability Council of TexasEmergency Management, Texas Division ofGrid Security Commission, TexasPublic Utility CommissionRailroad CommissionTerrorism & Internal Security
03

Senate Authors

Sen. Bob HallRepublican · Primary Author
Joint Authors
Coauthors (10)

House Sponsors

Rep. Terry WilsonRepublican · Primary Sponsor
Cosponsors (1)

Bill Text(with markup)

Showing first 50k characters.

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 SB75

Q

What does Texas SB75 do?

SB75 imposes immediate operational mandates on all Electric Generation and Transmission/Distribution Service Providers (TDSPs) to conduct biennial "physical attack" simulations coordinated with law enforcement. While the newly formed Texas Grid Security Commission (TGSC) has until late 2026 to develop long-term infrastructure hardening standards, market participants must immediately update Emergency Action Plans and prepare for mandatory reporting to ERCOT to avoid PUC enforcement actions.

Q

Who authored SB75?

SB75 was authored by Texas Senator Bob Hall during the Regular Session.

Q

When was SB75 signed into law?

SB75 was signed into law by Governor Greg Abbott on June 20, 2025.

Q

Which agencies enforce SB75?

SB75 is enforced by ERCOT, Public Utility Commission of Texas (PUC), Texas Division of Emergency Management (TDEM) and Texas Grid Security Commission (TGSC).

Q

How significant are the changes in SB75?

The regulatory priority for SB75 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of SB75?

The cost impact of SB75 is estimated as "medium". This may vary based on industry and implementation requirements.

Q

What topics does SB75 address?

SB75 addresses topics including disaster preparedness & relief, energy, energy--general, safety and state agencies, boards & commissions.

Q

What are the key dates for SB75?

Key dates for SB75: Effective date is 2025-09-01. Rulemaking: Submit report to Legislature recommending resilience standards and estimated implementation costs. (2026-12-01); Submit 'Plan for All Hazards Resilience' to Legislature, including EMP and cyber standards. (2026-12-01). Consult with legal counsel regarding applicability.

Q

What are the penalties under SB75?

SB75 establishes the following penalties: administrative penalty of Standard PUC administrative penalties (typically up to $25,000 per violation per day under Util. Code 15.023) for Failure to participate in mandatory load shedding/physical attack exercises or submit required attestations.. Consult with legal counsel for specific applicability to your situation.

Q

Which Texas businesses are affected by SB75?

SB75 primarily affects energy companies and power generators, utility companies and energy 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