HB 3512: Texas AI Training Requirements for Government Employees

HB 3512 is the Texas AI training mandate that most agencies know about but few have operationalized. It requires annual DIR-certified AI training for state employees who use computers for 25% or more of their job duties. The requirement is straightforward — the operational challenge is tracking compliance across hundreds or thousands of employees.

Who Must Complete HB 3512 Training?

The eligibility threshold is simple but broad:

• Any Texas state employee whose job duties involve computer use for 25% or more of their working time
• This includes full-time, part-time, and contract employees performing state functions
• It applies across all state agencies, not just IT departments
• Local government employees under state agency oversight may also qualify depending on agency policy

In practice, this captures most state employees. Administrative staff, analysts, case workers, IT professionals, managers, legal staff, communications officers — anyone who works on a computer a quarter or more of the day.

What the Training Must Cover

HB 3512 doesn't prescribe a specific curriculum, but training programs must be certified by the Department of Information Resources (DIR). DIR-certified programs typically cover:

• AI fundamentals. What AI is, how it works at a conceptual level, types of AI systems (ML, NLP, computer vision, generative AI).
• AI in government context. How state agencies use AI, appropriate vs. inappropriate applications, decision-support vs. autonomous systems.
• Ethics and bias. AI bias sources, fairness considerations, disparate impact awareness, and responsible use principles.
• Texas regulatory framework. Overview of TRAIGA, SB 1964, and employee obligations under state AI policy.
• Security and privacy. Data handling in AI systems, prompt injection risks, output verification, and confidential information protection.
• Practical application. How to evaluate AI outputs, when to escalate to human review, and how to report AI-related concerns.

Compliance Timeline

• Certification period: One year from completion date
• Renewal: Annual — employees must recertify each fiscal year (September 1 – August 31)
• FY2026 deadline: Training must be completed by August 31, 2026
• New hires: Should complete training within 90 days of start date (agency policy may vary)

Agencies that wait until Q4 (June-August) to schedule training face capacity constraints — DIR-certified programs have limited availability, and rushing training undermines retention. Best practice is to complete the bulk of training in Q1-Q2 (September-February) with makeup sessions in Q3.

What Records You Must Maintain

HB 3512 compliance isn't just about completing training — it's about documenting completion. For each employee, your records should include:

• Employee name and role
• Computer usage percentage (documentation of the 25%+ threshold)
• Training program name (must be DIR-certified)
• Certified by (the program provider and DIR certification reference)
• Completion date
• Expiration date (one year from completion)
• Certificate URL or ID (if the program issues one)
• Fiscal year (e.g., FY2026)

These records are subject to DIR reporting requirements under SB 1964 and may be requested during audits or AG investigations.

The Tracking Problem

For a small agency with 50 employees, a spreadsheet works. For a large agency with 5,000+ employees across multiple divisions and locations, manual tracking falls apart:

• Eligibility determination — who actually meets the 25% threshold? Job descriptions don't always reflect reality.
• Completion monitoring — tracking who has completed, who is in progress, and who hasn't started across thousands of people.
• Expiration alerts — certifications expire annually. Without automated alerts, employees lapse silently.
• New hire onboarding — ensuring new employees are flagged and scheduled within the 90-day window.
• Reporting — generating compliance reports for DIR, agency leadership, and audit requests.

This is a data management problem, not a training content problem. The training itself is straightforward. The operational challenge is ensuring every eligible employee completes it on time, every year, with documented proof.

How HB 3512 Fits the Bigger Picture

HB 3512 training is one piece of the triple compliance obligation for Texas government agencies:

1. TRAIGA (HB 149): Prohibited practice screening + NIST alignment for all AI systems
2. SB 1964: Ethics code + public AI inventory + heightened scrutiny assessments
3. HB 3512: Annual DIR-certified training for eligible employees

Training completion directly affects your compliance score. An agency with perfect TRAIGA screening and a solid ethics code but 40% training non-compliance has a visible gap that weakens both its governance posture and its affirmative defense.

Automate Training Tracking

TXAIMS includes a dedicated HB 3512 training tracker for government deployers. Register employees, log DIR-certified completions, track expirations, and generate compliance reports. Training records feed directly into your evidence bundles and compliance score — so your training compliance strengthens your NIST affirmative defense documentation automatically.