TDLR's Lawful Presence Requirement for Texas Licenses

Which licenses are covered

Every TDLR-regulated profession is subject to this requirement — there are no trade exemptions. That includes electricians, HVAC technicians, plumbers, barbers and cosmetologists, water well drillers, tow operators, massage therapists, property tax professionals, and all other TDLR licensees.

The enforcement date that matters for most active license holders is May 1, 2026. If your license comes up for renewal on or after that date, you will be required to submit lawful presence documentation as part of your renewal application. Renewing before May 1 will not trigger the requirement.

Documents TDLR accepts

TDLR accepts federal immigration and identity documents. The following satisfy the lawful presence requirement:

• U.S. Passport or Passport Card — covers all U.S. citizens
• Permanent Resident Card (Green Card / Form I-551)
• Employment Authorization Document (EAD / Form I-766) — covers DACA recipients, work-authorized visa holders, and asylum applicants with work authorization
• Refugee Travel Document (Form I-131) — for refugees and asylees
• Form I-94 — when it reflects refugee or asylee status
• Other federal documentation — TDLR has indicated it will publish a final list at tdlr.texas.gov before May 1

Most U.S. citizens will satisfy this with a passport. Most non-citizens will use their Green Card or EAD. If your situation is more complex — pending asylum, expiring work authorization, or unusual visa status — contact TDLR before your renewal deadline at 1-800-803-7233.

This is separate from the SSN requirement

TDLR is implementing two distinct requirements on the same May 1, 2026 deadline. They are not interchangeable:

• Lawful presence requirement — proves you are legally authorized to be in and work in the United States (this page)
• SSN/ITIN requirement — provides a tax and identity identifier for enforcement purposes. See our TDLR SSN requirement guide

Both are mandatory. Satisfying one does not satisfy the other. A worker with a valid SSN but no lawful presence document will be denied. A worker with a Green Card but no SSN or ITIN will also be denied.

What happens if you cannot comply

TDLR will not issue or renew a license without lawful presence documentation. There is currently no published grace period or alternative process. Workers who cannot provide qualifying documents when their license comes up for renewal will lose their ability to legally work in their trade once the current license expires.

The estimated 18,000 affected workers are concentrated in trades with historically immigrant workforces — cosmetology, electrician, HVAC, and plumbing are the highest volume. For employers and contractors, this means workers with upcoming renewal dates are a workforce risk: an active license today does not guarantee a renewable license in 2026. Check renewal dates now using LicenseStatusVerify, then have direct conversations with staff before the deadline arrives.