Texas AI policy

Texas School AI Rules Without TEA Guidance: HB 3512, TRAIGA, SB 1964, and What Districts Should Adopt

Texas has no education-agency AI guidance, so districts assume they have no obligations. They have four: AI awareness training under HB 3512, the state AI code of ethics and heightened-scrutiny review under SB 1964 and the DIR rule effective March 18, 2026, disclosure and prohibited-practice duties under TRAIGA effective January 1, 2026, and the existing student online personal information protections in the Education Code.

Audience
Texas superintendents, school boards, technology and cybersecurity coordinators, curriculum leaders, privacy officers, and district counsel
Read time
14 min read
Published
Reviewed
Review
TrueMadeAI Engineering
Review scope
Mapping of the statutory and rule duties to district owners, records, notices, and technical control points

Current status: Last reviewed September 7, 2026. This resource summarizes enrolled Texas bill text, the adopted Department of Information Resources rule, and cited public sources as read on that date. It is not legal advice. Texas districts should confirm scope, deadlines, and remediation with district counsel and the responsible state agencies.

Texas districts keep being told they are waiting on the state. They are not waiting. Three laws already apply, one administrative rule took effect in March 2026, and the Texas Education Agency has published nothing about AI at all. That combination is unusual: the duties arrived through the state technology and business codes rather than the Education Code, so they landed on the technology director’s desk without ever appearing in an agency letter to superintendents.

This page synthesizes what actually applies to a Texas school district today, names one bill that districts still cite but that never became law, and lays out what to adopt locally while the education agency stays silent.

The district templates that support this work, an application register, a tool vetting template, and an acceptable-use checklist, are in the free district AI governance starter kit.

What applies to a Texas district today

Source Status and effective date Reaches school districts because Core duty
HB 3512 (89th Legislature, 2025) Law, effective September 1, 2025 Amends the Government Code training requirement for local governments and adds an Education Code provision for districts Require certified artificial intelligence awareness training alongside the existing cybersecurity training, verify and report completion, and require periodic audits
SB 1964 (89th Legislature, 2025) Law, effective September 1, 2025 School districts are local governments under the Government Code definition Adopt the state AI code of ethics and the minimum standards for heightened-scrutiny AI, review deployment and use of covered systems and provide the review to the state on request, and use the standardized notice for public-facing or consequential-decision AI
1 Texas Administrative Code Chapter 219 Adopted rule, effective March 18, 2026 The rule states that state agencies and local governments shall adopt the AI code of ethics Implements SB 1964: definitions, the seven-principle code of ethics, risk management, risk assessment, impact assessment, and framework guidelines
HB 149, the Texas Responsible Artificial Intelligence Governance Act Law, effective January 1, 2026 Defines a governmental entity to include administrative units of political subdivisions, excluding only hospital districts and higher education Disclose to a person that they are interacting with an AI system, clearly and conspicuously and without a dark pattern; prohibitions on social scoring and on biometric identification from certain sources; attorney general enforcement
Texas Education Code Chapter 32, Subchapter D Law since 2017 Applies to operators of K-12 sites and services Bars targeted advertising to students, profiles other than for school purposes, and selling or renting student covered information. Predates AI but governs AI vendors handling student data

Two of these are governance duties about how the district uses AI, one is a training duty about staff, and one is a vendor duty the district enforces through contracts. None of them tells a teacher what a student may do with a chatbot. That gap is the district’s to fill.

The bill that is not law

Districts and vendors still circulate SB 747 as a Texas AI deepfake requirement for schools. It is not one. The bill passed the Senate in April 2025 and was reported from House Public Education in May, but its last action was placement on a calendar; it did not become law. Any district policy or vendor claim that cites SB 747 as an obligation should be corrected.

Separate 2025 laws do address synthetic sexual imagery, including an offense covering obscene visual material that appears to depict a child and that was created using an artificial intelligence application, and civil and criminal provisions on artificial intimate visual material. Those are criminal and civil matters. They do not create a district policy duty, though they belong in the district’s incident response planning. The K-12 AI incident response playbook covers the workflow when synthetic imagery involves students.

HB 3512: the training duty nobody scoped

HB 3512 folded artificial intelligence into the state’s existing training requirement for local government employees and officials. The Department of Information Resources certifies the training programs; by mid-2026 the department reported dozens of certified programs and offers a free training video.

The scoping question matters more than the requirement. The Government Code provision reaches employees and officials with access to a local government computer system or database whose duties include significant computer use. The Education Code provision addressing school districts identifies the district’s cybersecurity coordinator as required to complete the training annually. Districts have read that pairing two ways: narrowly, as the coordinator alone, and broadly, as the coordinator plus the wider group the Government Code describes.

That is a question for district counsel, not for a marketing page. What every district should do regardless is keep the evidence: who was in scope, which certified program they completed, when, and the governing body’s verification and reporting record. A district that cannot produce completion evidence has a documentation problem whichever reading is correct.

SB 1964 and the DIR rule: the governance duties

SB 1964 applied public-sector AI governance to local governments, and the Department of Information Resources rule that implements it took effect March 18, 2026. For a district, three obligations follow.

Adopt the AI code of ethics. The statute and the rule both say state agencies and local governments shall adopt it. This is a board or administrative adoption with a record, not a technical task.

Adopt the heightened-scrutiny minimum standards and review covered deployments. Districts must review the deployment and use of heightened-scrutiny AI systems and provide that review to the department on request. There is no statutory date attached, which means the district needs a review that exists before someone asks for it. A district cannot produce that review without an inventory.

Use the standardized notice. Where a local government uses public-facing AI or AI that controls a consequential decision, the state notice must appear on the related applications, websites, and public computer systems. The department publishes an AI System Facts template and a chatbot notice example.

A parent-facing chatbot on a district website is the clearest case: it is public facing, it needs the notice, and it is the kind of deployment a heightened-scrutiny review should cover. The parent-facing chatbot guide works through that use case, and the AI application register is where the inventory that feeds the review lives.

TRAIGA: disclosure and prohibitions

The Texas Responsible Artificial Intelligence Governance Act took effect January 1, 2026. Its definition of a governmental entity covers administrative units of political subdivisions and excludes only hospital districts and institutions of higher education, so districts should assume the governmental-entity provisions reach them and confirm the scope with counsel.

Three parts matter for a district:

  • Disclosure. A governmental entity that makes an AI system available to interact with people must disclose that fact clearly and conspicuously, in plain language, without using a dark pattern. This overlaps with the SB 1964 notice duty; a district can satisfy both with one well-placed notice, but it should decide deliberately rather than assume.
  • Social scoring and biometric identification prohibitions apply to governmental entities.
  • Attorney general enforcement. Enforcement authority sits with the attorney general rather than a private right of action.

One nuance worth raising with counsel: the act’s definition of a consumer excludes a person acting in a commercial or employment context, which raises a real question about whether staff-facing internal tools fall inside the disclosure duty. That is exactly the kind of ambiguity a district should resolve in writing rather than by default.

What the Texas Education Agency has not issued

As of September 7, 2026, no AI guidance document, framework, or resource page for districts was found on the agency’s site, and its technology planning page does not mention artificial intelligence. Searches surface training slides, cybersecurity letters, and assessment materials rather than instructional or governance guidance.

The agency does use automated scoring for constructed responses on the state assessment, with human rescoring of a sample, and describes it as an automated scoring engine. A university-led Texas AI in education task force recommended in August 2026 that the state issue statewide guidance, which is itself evidence that none exists.

The practical consequence is that a Texas district writing an AI policy has no state model to adopt and no state deadline to hit. It has three sources of borrowed structure:

  • Association model policy. The Texas Association of School Boards policy service added a technology resources policy code covering artificial intelligence and revised its training policy to reflect HB 3512. Districts across the state have been adopting it through the normal update cycle. Association model policy is not state guidance, and a district still owns the local decisions inside it.
  • Regional service centers and educator associations publish adoption checklists and tool guidance that cite national frameworks rather than Texas statutes.
  • Peer districts. Houston ISD published an AI guidebook, updated in January 2026, with student and staff guidelines and a vetted tool list. Cypress-Fairbanks ISD took a local AI policy through board readings in spring 2026, including language that AI tools may be used only with teacher permission.

A Texas district adoption plan

The statutes give a district four things to produce. The instructional questions the statutes do not answer are the fifth.

1. An inventory that can survive a state request

Every AI system the district deploys or uses, with owner, purpose, data touched, whether it is public facing, whether it informs a consequential decision, and the review date. This single record feeds the heightened-scrutiny review, the notice decision, the vendor contract file, and any future state guidance. Start it in the AI application register.

2. Adopted governance documents

The AI code of ethics adoption record, the heightened-scrutiny standards, and the local AI policy. Association model language gives a starting point; the K-12 AI acceptable use policy checklist covers what the policy text must address for students and staff.

3. Notices that are actually posted

The AI System Facts notice on public-facing systems and consequential-decision systems, plus the TRAIGA disclosure. Decide once, in writing, which notice satisfies which duty and where it appears.

4. Training evidence

Certified AI awareness training completion for whoever counsel scopes in, with the verification and reporting record the statute contemplates.

5. The classroom rules the statutes do not write

Texas law tells the district how to govern its own AI deployments. It says nothing about whether a seventh grader may use a chatbot for a draft, what a teacher may put into an AI grading assistant, or what happens when a student pastes a classmate’s name into a prompt. Those rules are local, and they are the ones families and teachers will ask about first.

The AI assistance ladder gives language for how much help is allowed by assignment type, the data boundaries guide covers what student information may reach a model, and the guide to governing student AI tools explains the four-layer model behind both.

How Tenet may support a Texas implementation

Tenet by TrueMadeAI is K-12 AI governance software. Tenet Edge applies district and classroom policy on supported direct-use AI surfaces on managed Chrome. Tenet Gateway is a founding-district program for approved backend AI operations such as a parent-facing assistant.

A Texas district implementation could use Tenet to help:

  • maintain one register of approved AI surfaces that feeds the heightened-scrutiny review and the notice decision;
  • present role, class, subject, and schedule-aware rules on supported surfaces, which is the classroom layer no Texas statute writes;
  • apply supported on-device data-loss-prevention controls before student text leaves the device, which supports the Education Code student-information protections;
  • block supported unapproved AI chat and writing interfaces when the district enables that control; and
  • route approved backend AI operations, including a public-facing assistant that needs the state notice, through defined application, purpose, data, model, and audit boundaries.

Tenet does not replace legal review, board adoption, procurement, the district’s training obligations, or its determination of which systems are heightened scrutiny under state standards. Coverage depends on the specific product surface; review the dated capability matrix before relying on a particular behavior.

If your district wants to map the Texas duties to owners, records, notices, and supported controls, request a scoped Tenet District conversation.

What this guide does not establish

This guide does not determine:

  • how broadly the HB 3512 training requirement scopes at your district;
  • whether a particular district AI system is heightened scrutiny under the state standards;
  • whether TRAIGA’s disclosure duty reaches a staff-facing internal tool;
  • that association model policy satisfies a statutory duty; or
  • the legal consequence of a missing adoption, notice, or training record.

Those conclusions require the current official sources, the district’s facts, and Texas counsel.

Sources

Frequently asked questions

Does Texas require school districts to have an AI policy?

No Texas law requires a school district to adopt a standalone AI-use policy the way Ohio, Oklahoma, Maryland, and North Carolina do. Texas instead imposes AI duties on districts as local governments: awareness training under HB 3512, the state AI code of ethics and heightened-scrutiny review under SB 1964 and the Department of Information Resources rule, and disclosure and prohibited-practice duties under the Texas Responsible Artificial Intelligence Governance Act.

Has the Texas Education Agency issued AI guidance for districts?

No AI guidance document, framework, or resource page for districts was found on the agency’s site as of September 7, 2026, and its technology planning page does not mention artificial intelligence. Districts have been filling the gap with association model policy and their own guidebooks.

Does TRAIGA apply to Texas school districts?

The act defines a governmental entity to include administrative units of a political subdivision, and excludes only hospital districts and institutions of higher education. School districts are political subdivisions, so districts should assume the governmental-entity provisions reach them and confirm scope with counsel.

What does SB 747 require of Texas schools regarding AI deepfakes?

Nothing. SB 747 passed the Senate in 2025 but died in the House and did not become law. Districts should not cite it as a requirement. Separate 2025 laws address artificial intimate imagery and AI-generated obscene material as criminal or civil matters rather than district duties.

Who at a Texas district must complete AI awareness training?

HB 3512 adds artificial intelligence training to the existing state training requirement for local government employees and officials with computer-system access whose duties involve significant computer use, with programs certified by the Department of Information Resources. The Education Code provision addressing districts identifies the district cybersecurity coordinator as required to complete the training annually. Districts should read the full subsection with counsel before scoping their roster.

What should a Texas district adopt while waiting for state guidance?

An AI application register, an approval workflow, the required AI System Facts notice for public-facing or consequential-decision AI, an acceptable-use policy covering students and staff, a data-boundary rule for student information, and evidence of AI awareness training. Association model policy language exists and several large districts have published their own guidebooks.

Texas readiness

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  • AI governance readiness assessmentScore your district across decision rights, inventory, privacy, instruction, controls, and evidence.
  • AI tool vetting and approval templateThe questions to ask before an AI product reaches students or staff.
  • AI application register templateOne place to record every approved AI surface, owner, data boundary, and review date.
  • K-12 AI acceptable use policy checklistWhat a defensible student and staff AI policy must cover.