When did SB 1964 take effect?

SB 1964 (89th Legislature, Regular Session) is effective September 1, 2025, so it is now in effect. Consult your counsel about how its specific provisions apply to your governmental entity.

Does SB 1964 apply to a hospital district?

It may. A hospital district can be a governmental entity, which could bring it within SB 1964’s scope, but this depends on the statutory definitions and your specific structure. Do not assume either way — confirm applicability with counsel.

What are the specific obligations under SB 1964?

SB 1964 touches government AI use and data management, ethics, procurement, the role of the Texas Department of Information Resources (DIR), and a Public Sector Artificial Intelligence Systems Advisory Board. We describe it at this verified level rather than restate granular sub-provisions; for the specific requirements that apply to your entity, see the statute and consult counsel.

How is SB 1964 different from TRAIGA?

They address different audiences, but both reach government. TRAIGA (HB 149) is an intent-based prohibition statute that applies broadly (in force January 1, 2026), enforced exclusively by the Texas Attorney General — with a 60-day cure period, no private right of action, a rebuttable presumption of reasonable care (§ 552.105(c)), a civil investigative demand the AG can issue (§ 552.103), tiered penalties (§ 552.105), and license sanctions for licensed personnel (§ 552.106). Governmental entities are also subject to TRAIGA’s governmental-only provisions — consumer-interaction disclosure (§ 552.051(b)), the social-scoring ban (§ 552.053), and biometric limits (§ 552.054). SB 1964 is separate: it governs how state agencies and local governments use AI and manage data (DIR, procurement, advisory board) and is already in effect as of September 1, 2025. Risk Meridian helps you keep one governance record you can draw on for each.

If TRAIGA applies to our agency, how is it enforced?

Through the Texas Attorney General only — there is no private right of action, and the AG must give written notice and a 60-day opportunity to cure before suing (§§ 552.101, 552.104). TRAIGA begins with a rebuttable presumption that you used reasonable care (§ 552.105(c)); a current governance record is how you preserve it. If the AG opens an investigation, a civil investigative demand can require a description of the system’s purpose, training data, input categories, outputs, performance metrics, known limitations, and your monitoring and oversight process (§ 552.103). Civil penalties are tiered — $10,000–$12,000 curable, $80,000–$200,000 uncurable, and $2,000–$40,000 per day continuing (§ 552.105) — and substantial compliance with the NIST AI RMF, among other routes, is a named affirmative defense (§ 552.105(e)). For licensed or certified personnel, a licensing agency may add sanctions up to suspension or revocation and a penalty up to $100,000, but only after a violation finding and an AG recommendation (§ 552.106). Confirm how these apply to your entity with counsel.

In effect — September 1, 2025Texas, USA

Texas SB 1964 Compliance Guide — Government AI & Data

What state agencies and local governments need to know about SB 1964 — the regulation and use of AI systems and the management of data by governmental entities, effective September 1, 2025.

Overview

Texas SB 1964 (89th Legislature, Regular Session) is captioned "Relating to the regulation and use of artificial intelligence systems and the management of data by governmental entities." Enacted in the 2025 session and effective September 1, 2025, it addresses how governmental entities in Texas use AI systems and manage data — touching government AI use and data management, ethics, procurement, the role of the Texas Department of Information Resources (DIR), and a Public Sector Artificial Intelligence Systems Advisory Board. SB 1964 is directed at governmental entities rather than private deployers. This guide describes the statute at a verified level; consult the statute text and your counsel for the specific, granular obligations that apply to your entity.

Who must comply?

SB 1964 applies to governmental entities in Texas — state agencies and local governments. It is not a general mandate on private companies. Some special-purpose governmental units may also fall within scope: a hospital district, for example, may qualify as a governmental entity, but this depends on the statutory definitions and your specific structure. Confirm applicability with counsel before relying on any scope conclusion.

Quick Facts

Framework: Texas SB 1964 — Government AI & Data
Jurisdiction: Texas, USA
Status: In effect — September 1, 2025

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Key obligations under Texas SB 1964

What your organization must actually do to comply — broken down by obligation category.

Governmental-Entity Scope

SB 1964 is aimed at governmental entities — state agencies and local governments — rather than private deployers. The precise definition of a governmental entity, and whether a special-purpose unit such as a hospital district is included, turns on the statute; confirm your status with counsel.

Government AI Use & Data Management

The statute addresses how governmental entities use AI systems and how they manage data in connection with that use. The specific requirements are set out in the statute — see the statute text and consult counsel for the granular obligations that apply to your entity.

Ethics & Responsible Use

SB 1964 touches ethics and responsible use of AI by governmental entities. Rather than restate specifics we cannot verify, we point you to the statute and counsel; Risk Meridian helps you document responsible-use decisions with written rationales.

Procurement Considerations

The statute touches procurement of AI systems by governmental entities. Because the detailed procurement provisions live in the statute, confirm them with counsel; Risk Meridian helps track vendor clauses and assessments across the procurement lifecycle.

Texas DIR Role

SB 1964 involves the Texas Department of Information Resources (DIR). The specific DIR-facing duties and submissions are defined by the statute and any DIR guidance — see the statute and consult counsel for what your entity must provide and when.

Public Sector AI Systems Advisory Board

The statute establishes a Public Sector Artificial Intelligence Systems Advisory Board. For the board’s exact composition, mandate, and how its guidance may affect your entity, refer to the statute and consult counsel.

What is Texas SB 1964?

SB 1964 (89th Legislature, Regular Session) is a Texas statute captioned "Relating to the regulation and use of artificial intelligence systems and the management of data by governmental entities." It became effective September 1, 2025. It addresses government AI use and data management, ethics, procurement, the role of the Texas Department of Information Resources (DIR), and creates a Public Sector Artificial Intelligence Systems Advisory Board. Because we describe SB 1964 only at the level we can verify, treat this guide as an orientation and rely on the statute text and your counsel for specific obligations.

Who does SB 1964 apply to?

SB 1964 is directed at governmental entities in Texas — state agencies and local governments — not at private companies as a general matter. Some special-purpose governmental units may also be within scope: a hospital district, for instance, may qualify as a governmental entity depending on the statutory definitions and your specific structure. If your organization is a hospital district or another special-purpose unit, confirm applicability with counsel before drawing conclusions.

DIR and the Public Sector AI Systems Advisory Board

SB 1964 involves the Texas Department of Information Resources (DIR) and establishes a Public Sector Artificial Intelligence Systems Advisory Board. The precise DIR-facing duties, any submissions, and the board’s composition and mandate are set out in the statute and any related guidance. For the details that determine what your entity must do, and by when, see the statute and consult counsel.

How to prepare for SB 1964

Because SB 1964 is in effect as of September 1, 2025, governmental entities should be documenting how they select, assess, and govern AI systems, and how they manage the associated data. Maintaining written rationales for AI decisions, versioned assessments, and a clear record of vendor commitments positions your entity to respond to DIR-facing requirements and advisory-board guidance. Risk Meridian supports this recordkeeping; confirm the specific statutory requirements with counsel.

TRAIGA also reaches government — and how it is enforced

SB 1964 is not the only Texas AI law that touches governmental entities. TRAIGA (HB 149, Business & Commerce Code ch. 552, in force January 1, 2026) applies to state agencies and local governments too: a governmental agency that makes an AI system available to interact with consumers must disclose that (§ 552.051(b)); governmental entities are specifically barred from AI social scoring (§ 552.053) and certain biometric identification (§ 552.054); and the general prohibitions apply as well (§§ 552.052, 552.055–552.057). TRAIGA is enforced exclusively by the Texas Attorney General, with a 60-day cure period and no private right of action (§§ 552.101, 552.104). It starts from a rebuttable presumption that you used reasonable care (§ 552.105(c)); if the AG investigates, a civil investigative demand can require a description of a system’s purpose, training data, inputs, outputs, metrics, limitations, and your oversight process (§ 552.103) — exactly the record a governance program keeps. Penalties run $10,000–$12,000 (curable), $80,000–$200,000 (uncurable), and $2,000–$40,000 per day (continuing) (§ 552.105), and for licensed or certified personnel a licensing agency may add sanctions — up to suspension or revocation and a penalty up to $100,000 — but only after a violation finding and an AG recommendation (§ 552.106). Note that TRAIGA expressly excludes hospital districts and public universities from its “governmental entity” definition (§ 552.001(3)), so those governmental-only provisions do not bind them under that chapter. SB 1964 adds its own governmental AI-use, data-management, procurement, DIR, and advisory-board structure on top of this.

How Risk Meridian helps

Meet Texas SB 1964 requirements with Risk Meridian

Government is our depth. Risk Meridian’s governmental-AI module includes a governmental-AI classifier that produces written rationales, versioned assessments you can revisit over time, a DIR submission pack to help assemble what governmental entities may need to provide, and vendor-clause tracking across procurement. We also surface hospital-district considerations so special-purpose units can evaluate whether they fall within scope. Risk Meridian helps you build a defensible record; it does not replace legal advice on how SB 1964 applies to your entity. The same record helps preserve TRAIGA’s rebuttable presumption of reasonable care (§ 552.105(c)) and answer a civil investigative demand (§ 552.103) if the Attorney General ever asks.

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What Risk Meridian covers for Texas SB 1964

Governmental-Entity Scope
Government AI Use & Data Management
Ethics & Responsible Use
Procurement Considerations
Texas DIR Role
Public Sector AI Systems Advisory Board

Texas SB 1964 — frequently asked questions

Common questions from compliance officers, legal teams, and executives evaluating Texas SB 1964 compliance obligations.

When did SB 1964 take effect?: SB 1964 (89th Legislature, Regular Session) is effective September 1, 2025, so it is now in effect. Consult your counsel about how its specific provisions apply to your governmental entity.
Who does SB 1964 apply to?: SB 1964 applies to governmental entities in Texas — state agencies and local governments. It is not a general mandate on private companies. Some special-purpose units may also qualify; confirm your status with counsel.
Does SB 1964 apply to a hospital district?: It may. A hospital district can be a governmental entity, which could bring it within SB 1964’s scope, but this depends on the statutory definitions and your specific structure. Do not assume either way — confirm applicability with counsel.
What are the specific obligations under SB 1964?: SB 1964 touches government AI use and data management, ethics, procurement, the role of the Texas Department of Information Resources (DIR), and a Public Sector Artificial Intelligence Systems Advisory Board. We describe it at this verified level rather than restate granular sub-provisions; for the specific requirements that apply to your entity, see the statute and consult counsel.
How is SB 1964 different from TRAIGA?: They address different audiences, but both reach government. TRAIGA (HB 149) is an intent-based prohibition statute that applies broadly (in force January 1, 2026), enforced exclusively by the Texas Attorney General — with a 60-day cure period, no private right of action, a rebuttable presumption of reasonable care (§ 552.105(c)), a civil investigative demand the AG can issue (§ 552.103), tiered penalties (§ 552.105), and license sanctions for licensed personnel (§ 552.106). Governmental entities are also subject to TRAIGA’s governmental-only provisions — consumer-interaction disclosure (§ 552.051(b)), the social-scoring ban (§ 552.053), and biometric limits (§ 552.054). SB 1964 is separate: it governs how state agencies and local governments use AI and manage data (DIR, procurement, advisory board) and is already in effect as of September 1, 2025. Risk Meridian helps you keep one governance record you can draw on for each.
If TRAIGA applies to our agency, how is it enforced?: Through the Texas Attorney General only — there is no private right of action, and the AG must give written notice and a 60-day opportunity to cure before suing (§§ 552.101, 552.104). TRAIGA begins with a rebuttable presumption that you used reasonable care (§ 552.105(c)); a current governance record is how you preserve it. If the AG opens an investigation, a civil investigative demand can require a description of the system’s purpose, training data, input categories, outputs, performance metrics, known limitations, and your monitoring and oversight process (§ 552.103). Civil penalties are tiered — $10,000–$12,000 curable, $80,000–$200,000 uncurable, and $2,000–$40,000 per day continuing (§ 552.105) — and substantial compliance with the NIST AI RMF, among other routes, is a named affirmative defense (§ 552.105(e)). For licensed or certified personnel, a licensing agency may add sanctions up to suspension or revocation and a penalty up to $100,000, but only after a violation finding and an AG recommendation (§ 552.106). Confirm how these apply to your entity with counsel.

Other AI regulation guides

Texas TRAIGA

Texas, USA

EU AI Act

European Union

NIST AI RMF

United States (Federal)

ISO 42001

International

California AI

California, USA

Colorado AI Act

Colorado, USA

Texas HB 3512

Texas, USA

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