Christina Mathieson Segura | Real Estate Education

This is for real estate professionals working in Texas, and for anyone who wants to see what a solar accountability system looks like in its first week. It is educational. It is not legal advice, and I am not licensed in Texas. For a specific transaction, consult a Texas attorney.

 

What Actually Changed Today

Senate Bill 1036, authored by Senator Judith Zaffirini of Laredo and passed by the 89th Legislature, created Chapter 1806 of the Texas Occupations Code, the Residential Solar Retailer Regulatory Act. Most of it took effect September 1, 2025. Today is the second phase.

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As of today, residential solar retailers and individual solar salespersons must hold a TDLR registration to sell or lease residential solar in Texas. Certain prohibited acts under Section 1806.201, along with additional statutory requirements, became enforceable and subject to administrative action.

The first phase, a year ago, already required contract provisions, disclosures, and a five business day right to cancel.

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What TDLR covers, and what it does not, is worth learning precisely rather than roughly.

It covers sales and leases of residential solar energy systems, including most solar panels and solar shingles. It does not cover systems on multifamily buildings of four or more dwelling units or stories. It does not cover nonresidential property. It does not cover systems for temporary or emergency use, or systems powering a single appliance, or systems generating less than one kilowatt of peak output in the aggregate. Electrical contractors and their employees are exempt from registering, though they remain subject to most of the Act.

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And it does not cover power purchase agreements at all. More on that in a moment, because it is the biggest hole in the floor.

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The Thing Your Clients Can Use Tomorrow

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TDLR maintains a free public registry. Anyone can search it.

That is the practical takeaway, and it is genuinely new. Until today there was no way for a Texas homeowner to check whether the person standing on their porch was accountable to any state agency.

 

Now there is a name to look up and an agency that will take the complaint.

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For an agent, this is not a compliance obligation. It is a question you can ask that you could not ask before.

When a seller's file includes a solar contract, look at the paperwork and find the name of the company and, if it is there, the salesperson. Search both. Note what you find and note the date you searched. If the contract was signed on or after September 1, 2025, TDLR can take a complaint about it. If it was signed before that, the complaint goes to the Texas Attorney General's Consumer Protection Division instead. And TDLR can take complaints about electrical contractors for installation or repair work performed at any time, with no date limit.

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That last point is the one most people will miss. The installation is regulated separately from the sale, and always has been.

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Two Things That Would Be Easy to Get Wrong

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I want to be careful here, because a registry is the kind of tool that invites overconfidence in week one.

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The registry is nearly empty, and that is not the same as a fraud signal. Eighteen retailers and five hundred salespersons is a fraction of the people selling solar in Texas. Most of the companies operating there today are not in it. A name that does not appear is not evidence that anyone did anything wrong. It is evidence that the system is three weeks old.

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Treat an absent name as a question to raise, not a conclusion to draw. Say what you found and what you did not, and let the client and their attorney decide what it means. An agent who tells a seller their installer is unregistered and therefore illegitimate has made a claim they cannot support.

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TDLR announced a suspension, and its exact reach matters. On August 21, TDLR announced it is temporarily suspending enforcement of certain administrative rules until November 1, 2026, to give retailers time to adjust to the new compliance requirements. Coverage of that announcement has described its scope differently. KXAN reported it as covering contract disclosure requirements and educational brochures. Other outlets described it more broadly.

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Here is what I can state and what I cannot. The registration requirement is statutory, in Occupations Code Sections 1806.101 and 1806.102. A department suspending enforcement of its own rules is a different act from a statute not taking effect. Whether an unregistered salesperson faces administrative exposure today depends on exactly which rules TDLR listed, and I am not going to characterize that from news summaries. Read the August 21 notice on TDLR's site directly before you tell a client anything about it.

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The Hole in the Floor

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TDLR does not regulate power purchase agreements.

This is not an oversight in the rollout.

It is written into the program.

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In a power purchase agreement the homeowner does not buy the panels and does not lease them. The homeowner allows a company to put equipment on the roof and agrees to buy the electricity it produces. Because there is no sale and no lease, the transaction falls outside Chapter 1806.

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So consider two Texas homeowners on the same street with identical panels on identical roofs, sold by the same person on the same afternoon.

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The one who signed a loan or a lease now has a registry to search, a code of conduct that binds the seller, a five business day cancellation right, and an agency that will take the complaint.

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The one who signed a power purchase agreement has none of it.

No registration to look up.

No TDLR complaint path.

 

The Attorney General remains available, and the AG opened an initiative into residential solar on April 3, 2026 with civil investigative demands to four companies. But the AG builds patterns rather than resolving individual disputes, and its own guidance says a complainant may never be contacted again.

Same roof. Same salesperson. Same day. Different country, as far as the law is concerned.

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If you do one thing with this article, make it this: before you send a Texas client to TDLR, find out whether they have a loan, a lease, or a PPA. Sending a PPA client to an agency with no jurisdiction over their contract wastes weeks they may not have.

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What This Costs

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The honest accounting.

It costs the homeowners who signed before today, which is nearly all of them. A registry is forward-looking. It does not reach back and give a remedy to anyone already holding a bad contract, and Texas has a great many of those. Freedom Forever, the second largest residential installer in the country in 2025, filed Chapter 11 in Delaware on April 15, 2026, with a notice that no funds would be available for unsecured creditors after administrative expenses. Every Texas homeowner in that file is outside what happened today.

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It costs the honest retailers, who now carry registration, renewal, insurance, and code of conduct obligations while competitors who have not registered keep selling through a grace period. That is what a phased rollout does to the people who comply first.

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And it costs the argument I am making, so I will say it plainly. A registry does not fix a system that underproduces. It does not release a lien. It does not make a bankrupt installer honor a workmanship warranty. It tells you who someone is, which is worth having, and it is much less than what people will want it to be.

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A name missing from the registry is not evidence of anything yet. It is a question you can finally ask.

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What You Do With It

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You cannot register a company that will not register. You cannot give a power purchase agreement a complaint path the statute never built. You can look up a name, write down what you found, and hand it to your client before they sign anything.

Ask.

 

 

Sources: Texas Occupations Code Chapter 1806, Residential Solar Retailer Regulatory Act (SB 1036, 89th Legislature). Texas Department of Licensing and Regulation, Residential Solar Retailers program materials and August 21, 2026 program update. KTRK ABC13 Houston, September 1, 2026, reporting TDLR-provided registration figures. KXAN Austin, September 1, 2026. In re Freedom Forever LLC, Case No. 26-10522, United States Bankruptcy Court for the District of Delaware, filed April 15, 2026. Office of the Texas Attorney General, residential solar initiative announced April 3, 2026. Verified September 1, 2026