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Signed Into Law
Signed June 20, 2025Effective 2025-09-01
SB827

Regular Session

Relating to the audit of an election using an electronic voting system.

Government Affairs & Regulatory Compliance Analysis

SB827: Government Affairs Overview

SB827 mandates a transition from partial electronic audits to manual hand counts of specific polling locations and requires universal participation in risk-limiting audits (RLAs) for all Texas counties. This legislation directly impacts election system vendors' service level agreements (SLAs) regarding support windows and requires county administrators to reconfigure post-election staffing and reporting workflows.

Sen. Tan Parker·Senate Bill·Regular Session

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

General Custodian of Election Records (County Level) • Secretary of State

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SB827
Moderate
Relating to the audit of an election using an electronic voting system.
Moderate Compliance Urgency
Requires near-term attention
Cost Impact
Low
Effective
2025-09-01
Enforcing Agencies
General Custodian of Election Re...Secretary of State
Primary Author: Sen. Tan Parker
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: October 1, 2025 (to ensure readiness for the November 2025 election cycle).
  • Agency Rulemaking: The Secretary of State (SOS) is statutorily required to adopt rules defining polling location selection and RLA scheduling *prior* to the first applicable election. Expect a regulatory gray zone regarding specific audit protocols between September 1 and late October 2025.

Immediate Action Plan

  • 1. Audit Vendor Contracts: Immediately review SLAs to ensure support coverage extends 30 days post-election.
  • 2. Update Watcher Protocols: Revise legal guidance and training to direct watchers to the Presiding Judge of the EVBB for credentialing.
  • 3. Monitor the Texas Register: Assign a compliance officer to track SOS proposed rules regarding "polling location" definitions.
  • 4. Prepare Web Infrastructure: Direct IT to create a designated upload slot for audit results adjacent to election returns on the county website.

Operational Changes Required

Contracts

  • Vendor SLAs: Review and amend contracts with voting system providers (e.g., ES&S, Hart) to extend technical support and legal hold capabilities from the standard canvass period to a full 30-day post-election window to accommodate the new RLA timeline.
  • Performance Guarantees: Update liability clauses to address potential discrepancies found during manual hand counts versus electronic tabulation.

Hiring/Training

  • Watcher Training: Update training materials for poll watchers immediately. They must now present credentials to the Presiding Judge of the Early Voting Ballot Board, not the general custodian.
  • Staffing Allocation: Employers of election workers must anticipate extended leave requests; the audit window is no longer a fixed 24-hour period but depends on SOS scheduling.

Reporting & Record-Keeping

  • Public Posting: IT teams must configure county websites to post manual count results in the *exact same location* as election returns within 3 days of count completion.
  • SOS Filing: A written report of the manual count must be transmitted to the Secretary of State no later than the 3rd day post-count.

Fees & Costs

  • Operational Overhead: While the LBB notes no fiscal impact to the state, counties and vendors must budget for increased overtime and technical support hours to accommodate manual counting procedures.

Strategic Ambiguities & Considerations

  • RLA Scheduling: The law removes the fixed 24-hour start window, granting the SOS total discretion on dates. This makes precise workforce planning impossible until the SOS issues the election calendar.
  • Unit of Audit: The shift from "precincts" to "polling locations" creates uncertainty for Vote Centers. It is currently unclear if *all* ballots at a Vote Center must be hand-counted or only specific ballot styles; SOS rulemaking determines this scope.
  • Discrepancy Resolution: The statute does not explicitly define which count prevails for canvassing if the manual count contradicts the electronic tabulation, creating a specific litigation risk.

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Legislative Timeline

This bill's path through the Texas Legislature

Filed
Jan 16, 2025
Passed Senate
Apr 10, 2025
Passed House
May 24, 2025
Signed
Jun 20, 2025
Effective
Sep 1, 2025
TopicsElectionsElections--generalAudits & AuditorsCounty GovernmentCounty Government--generalElections--election OfficersElections--voting SystemsSecretary of State
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Senate Authors

Sen. Tan ParkerRepublican · Primary Author

House Sponsor

Rep. Mano DeAyalaRepublican · Primary Sponsor

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 SB827

Q

What does Texas SB827 do?

SB827 mandates a transition from partial electronic audits to manual hand counts of specific polling locations and requires universal participation in risk-limiting audits (RLAs) for all Texas counties. This legislation directly impacts election system vendors' service level agreements (SLAs) regarding support windows and requires county administrators to reconfigure post-election staffing and reporting workflows.

Q

Who authored SB827?

SB827 was authored by Texas Senator Tan Parker during the Regular Session.

Q

When was SB827 signed into law?

SB827 was signed into law by Governor Greg Abbott on June 20, 2025.

Q

Which agencies enforce SB827?

SB827 is enforced by General Custodian of Election Records (County Level) and Secretary of State.

Q

How significant are the changes in SB827?

The regulatory priority for SB827 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of SB827?

The cost impact of SB827 is estimated as "low". This may vary based on industry and implementation requirements.

Q

What topics does SB827 address?

SB827 addresses topics including elections, elections--general, audits & auditors, county government and county government--general.

Q

What are the key dates for SB827?

Key dates for SB827: Effective date is 2025-09-01. Rulemaking: Adopt rules for selecting polling locations/precincts for manual counts and prescribe dates for risk-limiting audits. (Prior to first applicable election). Consult with legal counsel regarding applicability.

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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