Since HB 3512 took effect on September 1, 2025, Texas cities and counties have had a second annual training requirement sitting next to cybersecurity training: artificial intelligence training. The law is short. Doing it cleanly takes a little planning.
Here is what the statute actually says, and a simple way to meet it without turning it into a scramble every August.
Who has to take it
Government Code Section 2054.5191(a-1) tells each local government to identify, at least once a year, the employees and elected and appointed officials who:
- have access to a local government computer system or database, and
- use a computer to perform at least 25 percent of their required duties.
Everyone who meets both parts completes a certified cybersecurity training program and a certified artificial intelligence training program. Every year.
Which program counts
Not any AI course. The program has to be certified under Government Code Section 2054.5193, and the state publishes the list of certified programs each year. Under Section 2054.5191(b), your governing body may select the most appropriate certified program for your employees and officials.
That choice is worth a few minutes of thought. Programs on the list differ in length, format, whether there is an assessment, and whether each person gets proof of completion. If you will have to show who finished and when, a program that gives you that record saves work later.
What the governing body has to do
The same subsection gives the governing body two jobs:
- Verify and report completion of the cybersecurity and AI training to the state.
- Require periodic audits to make sure the requirement is being met.
The state provides a form for reporting, and under Section 2054.5191(e) that form lets you show the percentage of employees who completed the training. The annual certification has been due August 31. Check the current form and date each year, because that is the one deadline that matters.
Why it is more than paperwork
For many cities and counties, the most expensive consequence has nothing to do with the training itself. Government Code Section 772.012 requires a local government to certify compliance with this training when it applies for certain state criminal justice grants, and a local government found out of compliance can be required to repay the grant. We walk through that rule in AI training and criminal justice grants.
A simple way to run it every year
1. Build the list once, then update it
Start from your payroll and account lists. Anyone with a local government login who does most of their work at a computer is a likely yes. Add elected and appointed officials. Keep the list in one place, and update it when people are hired, elected or leave.
2. Pick the program early
Choose from the certified list at the start of the year, not in July. Consider how people will actually complete it: a self-paced course for most staff, a live session for groups who do better together, and something that works for officials who are rarely at a desk.
3. Track completion as it happens
Keep a simple record for each person: name, department, program, date completed, and proof. If the program issues a completion record, save it. Chasing proof in August is where most of the stress comes from.
4. Put the report on the calendar
Assign one person to own the annual certification and give them a date well before the deadline. Have them check the completion percentage monthly from spring on.
5. Plan the audit
The law asks for periodic audits. Something as simple as a yearly spot check of completion records against your list, done by someone other than the person who kept them, is a reasonable start. Write down what you checked and when.
Common mistakes
- Treating it as a one-time course. It is annual.
- Leaving officials off the list. The statute names them.
- Using a course that is not certified. A good general AI course does not count if it is not on the certified list.
- Having no proof. A sign-in sheet with no dates is hard to stand behind.
- Waiting for August. Completion rates drop when training is squeezed into the last few weeks.
The requirement is not complicated. It just rewards the local governments that start early and keep records as they go.
Questions people ask
Which local government employees have to complete AI training in Texas?
Employees and elected or appointed officials who have access to a local government computer system or database and use a computer for at least 25 percent of their required duties. That comes from Government Code Section 2054.5191(a-1).
How often is the AI training required?
At least once each year. It sits alongside the cybersecurity training requirement, and both are annual.
Can we use any AI course?
No. The program has to be certified under Government Code Section 2054.5193. The state publishes the list of certified programs, and your governing body may choose the one that fits your employees best.
Do elected officials have to take it?
Yes, if they meet the same test as employees: access to a local government computer system or database and computer use for at least 25 percent of their duties.
What does the governing body have to do?
Verify and report completion of the cybersecurity and AI training to the state, and require periodic audits to make sure the requirement is being met.