State of Texas has enacted HB 149: The Texas Responsible AI Governance Act

What You Need to Know About HB 149 — the Texas Responsible AI Governance Act

Published: June 2025

Guiding responsible AI innovation: Navigating the intersection of technology and governance.

Overview

In a landmark move, the State of Texas has enacted House Bill 149—formally known as the Texas Responsible AI Governance Act (TRAIGA)—marking one of the most comprehensive state-level legislative efforts to regulate artificial intelligence in the United States. Effective January 1, 2026, the law establishes stringent requirements for both public institutions and private-sector entities deploying AI systems that affect Texas residents.

TRAIGA introduces a risk-based regulatory approach designed to balance innovation with accountability, placing new obligations on developers, deployers, and governmental users of AI systems.

Key Provisions

1. Restrictions on Certain AI ApplicationsTRAIGA prohibits the use of AI technologies in contexts deemed inherently high-risk or harmful. Specifically, it bans:

• The collection of biometric data—including facial recognition, voice prints, and retinal scans—without explicit user consent

• “Social scoring” systems

• AI applications designed to coerce behavior, incite criminal activity or self-harm

• Tools that may infringe upon political or constitutional rights

  
  

2. Mandatory Transparency and OversightThe law requires clear, proactive disclosure of AI usage by public agencies. Additionally, any organization deploying high-risk AI systems must conduct and document annual impact assessments that address:

• System purpose and intended outcomes

• Data provenance and quality assurance

• Bias detection and mitigation strategies

• Cybersecurity and risk controls

  
  

3. Enforcement and Penalties

TRAIGA grants enforcement authority to the Texas Attorney General. Organizations found in violation of the Act may face civil penalties of up to $200,000 per day until remediation measures are enacted. The law does not, however, grant a private right of action—placing the full enforcement burden with the AG’s office.

4. Innovation Sandbox

To promote responsible innovation, TRAIGA introduces a 36-month regulatory sandbox, allowing emerging AI companies to test new technologies under state supervision with temporarily reduced compliance obligations. This aims to accelerate market entry while embedding trust and accountability from the outset.

5. Establishment of a State AI Advisory Council

A newly formed 10-member AI Advisory Council will:

• Monitor AI deployment across state agencies

• Recommend best practices and policy updates

• Oversee the regulatory sandbox program

• Fund training and capacity-building initiatives for responsible AI development

Entities Affected

TRAIGA applies broadly across sectors and organizational sizes, including:

• Government agencies utilizing AI in public services

• Private companies offering AI-enabled products or services to Texas residents, including remote or online delivery

• Developers and deployers of high-risk AI systems, regardless of size or industry

Strategic Implications

The enactment of TRAIGA signals a growing shift toward state-level AI regulation in the U.S., reflecting both public concern and regulatory momentum. For organizations operating in or serving the Texas market, several implications are clear:

• Transparency is now a legal obligation. Ambiguous or generalized claims about AI systems will no longer suffice.

• Bias and risk assessments are required, not optional. Impact assessments must be systematic, auditable, and updated annually.

• The sandbox represents a dual opportunity—a safe space for innovation and a framework for long-term compliance readiness.

• Non-compliance carries significant financial consequences, reinforcing the need for proactive governance mechanisms.

• However, the lack of private litigation rights may limit stakeholder accountability outside of state enforcement.

TrustVector’s Perspective

At TrustVector, we view TRAIGA as a forward-looking effort to regulate AI thoughtfully—prioritizing public trust while encouraging responsible innovation. It is not a constraint, but an opportunity for organizations to embed governance principles early and position themselves as leaders in ethical AI deployment.

Our Services in Support of TRAIGA Compliance Include:

• Implementation of end-to-end Annual AI Impact Assessment frameworks

• Deployment of transparency and consent mechanisms tailored to public-facing AI systems

• Design of sandbox-aligned governance toolkits to support innovation and regulatory agility

• Pre-compliance audits and readiness assessments to mitigate enforcement risk

Prepare with Confidence

As AI regulation intensifies across jurisdictions, staying ahead requires not just awareness—but action. TrustVector enables organizations to operationalize responsible AI practices, align with emerging laws like TRAIGA, and build systems that earn trust at scale.