On June 22, 2025, Texas Governor Greg Abbott signed into law the Texas Responsible Artificial Intelligence Governance Act (“TRAIGA”), a cross-sectoral statute regulating artificial intelligence (AI) systems. TRAIGA will take effect on January 1, 2026. It introduces disclosure, conduct, and enforcement obligations that affect both public agencies and private entities operating or doing business in Texas.
TRAIGA’s enactment marks Texas as the fourth state to adopt a comprehensive AI governance regime, following California, Colorado, and Utah. Although federal legislation on AI remains under debate, including a proposed 10-year moratorium on state regulation, TRAIGA reflects a growing trend among states to preemptively govern AI risks and high-impact applications.
Scope and Applicability
TRAIGA prohibits the development, deployment, or distribution of AI systems that are intentionally designed to manipulate behavior, produce discriminatory outcomes, or generate harmful deepfakes (especially involving minors). The law further bans the capture of biometric identifiers without express consent and establishes disclosure requirements for government entities that deploy AI in public-facing services.
While many of the obligations apply specifically to state agencies, the law imposes meaningful restrictions on private-sector companies that develop or deploy AI tools in Texas. Importantly, TRAIGA includes a broad construction clause and per-violation penalties ranging from $80,000 to $200,000 if violations are not cured within 60 days. There is no private right of action; enforcement is exclusively vested in the Texas Attorney General.
Implications for Telecommunications Providers
Telecommunications companies, including facilities-based carriers, VoIP providers, and MVNOs, should carefully evaluate their exposure under TRAIGA. Many commonly used AI applications, such as automated customer segmentation, ad targeting, loyalty programs, or service optimization, could fall within TRAIGA’s scope depending on intent and impact.
Telecom providers that deploy AI-driven customer interaction systems, including chatbots or upsell tools, must assess whether such systems could be viewed as manipulating consumer behavior. Similarly, companies collecting call detail records (CDRs), network metadata, or voiceprints for fraud prevention, analytics, or personalization may be subject to biometric and behavioral use limitations.
Vendors serving Texas public agencies may be required to disclose how AI systems operate and what data they rely on. Telecom contractors to the state should also be aware that agencies must develop “acceptable use” policies and internal ethics guidelines under the new law.
Other Sector Considerations
TRAIGA’s prohibitions extend beyond telecom and may imply companies in adtech, biometrics, cloud AI services, and customer analytics. The law’s intent requirement means companies will need to show reasonable diligence and compliance efforts to mitigate enforcement risks. Although TRAIGA does not ban AI outright, companies must ensure their systems do not generate or reinforce harmful or discriminatory outcomes and are not deployed for exploitative purposes.
TRAIGA also establishes a regulatory sandbox for AI innovation under the Texas Department of Information Resources, allowing companies to test systems in a limited environment while insulating against certain liabilities—subject to approval.
Next Steps for Businesses
With the effective date approaching and the potential for significant penalties, businesses operating in or serving customers in Texas should begin reviewing their AI governance practices. We recommend:
- Auditing existing AI tools and vendor systems for potential manipulation, discrimination, or biometric data use.
- Updating contracts and terms of use reflect new disclosure and consent obligations.
- Implementing AI governance policies and employee training programs, especially for teams deploying or procuring AI tools.
- Engaging with the AI sandbox, if applicable, to limit compliance exposure for new models.
The CommLaw Group Can Help
If your company operates in telecommunications, technology, or data analytics and has questions about its obligations under the Texas AI law—or if you would like to assess your current AI deployment and compliance posture—please contact us:
Susan Duarte – Tel: 703-714-1318 / E-mail: sfd@commlawgroup.com
Diana James – Tel: 703-663-6757 / E-mail: daj@commlawgroup.com
Brian Alexander – Tel: 703-714-1321 / E-mail: bal@commlawgroup.com
