AI Compliance for Texas Government Agencies: SB 1964, HB 3512 & TRAIGA

If you work in a Texas state agency, local government, or school district, you don't just have to worry about TRAIGA. You have three overlapping compliance mandates, each with its own requirements and timelines.

The Three Laws

1. TRAIGA (HB 149) — Prohibited Practices + NIST Safe Harbor

Applies to every entity in Texas, including government. Your AI systems must be screened against the seven prohibited practices, and NIST AI RMF alignment serves as your affirmative defense. Government agencies are not exempt.

2. SB 1964 — AI Ethics Code for Government

Requires state agencies to:

• Adopt an AI ethics code — not optional, not aspirational
• Maintain an AI system inventory — every AI tool, vendor, and deployment
• Conduct heightened scrutiny assessments for AI systems that affect individual rights, benefits, or access to services
• Publish public disclosures when AI is used in citizen-facing decisions
• Designate an AI ethics officer or equivalent role

3. HB 3512 — Mandatory AI Training for State Employees

Every state employee who uses a computer for 25% or more of their job duties must complete annual AI training certified by the Texas Department of Information Resources (DIR). That's most of your workforce.

• Annual certification requirement
• DIR-approved curriculum
• Training records must be maintained for audit
• Non-compliance affects agency audit scores

Where They Overlap

The complexity isn't in any single law — it's in the intersections:

• TRAIGA requires prohibited practice screening → SB 1964 requires the same systems to have ethics reviews → the ethics review should incorporate TRAIGA screening
• SB 1964 requires an AI inventory → TRAIGA requires NIST alignment documentation for each system → your inventory is the foundation of your NIST MAP function
• HB 3512 training must cover AI ethics → those ethics are defined by SB 1964 → which references TRAIGA prohibited practices

Do them separately and you triple the work. Integrate them and they reinforce each other.

The Government Compliance Score

TXAIMS uses a government-specific scoring model that weights all three statutes:

• SB 1964 Ethics Code (20 points) — policy adoption, officer designation, review cadence
• AI System Inventory (15 points) — completeness, currency, documentation quality
• Heightened Scrutiny Assessments (20 points) — rights-affecting systems reviewed
• Public Disclosures (15 points) — citizen-facing AI transparency
• HB 3512 Training (15 points) — completion rate, certification tracking
• Government AI Bans (15 points) — restricted use compliance

Practical Steps for Agency CIOs

1. Start with the inventory. You can't comply with any of the three laws without knowing what AI you're using.
2. Designate an AI ethics officer. This doesn't have to be a new hire — it can be an existing compliance or legal lead with expanded responsibility.
3. Adopt your ethics code early. DIR is watching. Being among the first agencies to adopt signals leadership.
4. Deploy training before the audit cycle. HB 3512 training records are auditable. Get ahead of it.
5. Use one platform for all three. Separate spreadsheets for TRAIGA, SB 1964, and HB 3512 will collapse under their own weight.

TXAIMS for Government is purpose-built for this triple compliance challenge. One platform, one score, one evidence bundle covering all three statutes. Start your 14-day trial.