If you sell or install residential solar panels in Texas, you have about six weeks left to get your paperwork in order. Starting September 1, 2026, every residential solar retailer and solar salesperson operating in the state must be registered with the Texas Department of Licensing and Regulation (TDLR) — and the agency now has real enforcement teeth, including fines that double when the customer is over 65.
Senate Bill 1036, the Residential Solar Retailer Regulatory Act, has been phasing in since last year. The contract and disclosure rules already took effect in September 2025. What changes on September 1, 2026 is registration itself, plus TDLR's full authority to investigate complaints and issue penalties. If your business sells, leases, or arranges financing for residential solar installations in Texas, here's what actually changes and what you need to do before the deadline.
Why Texas Passed This Law
Residential solar sales have a reputation problem, and not an unfair one. Door-to-door and telemarketing-driven solar sales have generated a steady stream of consumer complaints nationwide: inflated savings projections, financing terms that weren't clearly disclosed, salespeople claiming to be affiliated with the customer's utility, and homeowners locked into 20-25 year loan or lease obligations they didn't fully understand.
Texas lawmakers responded with SB 1036, which does two things. First, it standardizes what a residential solar contract has to disclose and give the customer the right to walk away from. Second, it creates a licensing regime — administered by TDLR, the same agency that already licenses electricians, HVAC contractors, and dozens of other trades — so the state can track who is selling solar and discipline bad actors.
The Two-Phase Rollout
SB 1036 didn't flip on all at once. It's been a two-step implementation, and understanding both steps matters because some obligations already apply to you.
Phase 1 — September 1, 2025 (already in effect):
- Every residential solar contract must state that installation will be performed by a licensed electrical contractor, and must name that contractor and their license number.
- Contracts must include a right-to-cancel clause: the buyer or lessee can cancel without penalty within five business days after the later of contract execution or receipt of the required disclosures.
- If a third-party lender financed the deal, the lender must cancel the associated loan if the underlying solar contract is cancelled.
- The retailer or contractor is responsible for pulling necessary permits and securing utility interconnection approvals.
Phase 2 — September 1, 2026 (the deadline you're reading this for):
- Residential solar retailers (the business) and solar salespersons (individuals selling on commission or for compensation) must be registered with TDLR before conducting any residential solar sales or leases in Texas.
- TDLR's code of conduct — a list of prohibited sales practices — becomes fully enforceable, with real penalties attached.
- TDLR gains full investigative and disciplinary authority over registrants, including the ability to suspend or revoke registration.
If your contracts and disclosures were already updated for the 2025 phase, you're halfway there. The registration step is the part that's easy to underestimate because it's an administrative filing, not a sales-floor change — but operating unregistered after September 1, 2026 is itself a violation.
Who Has to Register
- Residential solar retailers — any business that employs or contracts with individuals to sell or lease residential solar panels or residential solar energy systems to Texas homeowners.
- Solar salespersons — individuals who sell or lease residential solar systems for compensation, unless they are already a licensed electrical contractor selling under that license.
Exemptions: licensed electrical contractors performing installation work under their existing TECL license, and manufacturers selling systems they made themselves, fall outside the registration requirement. They're not off the hook entirely, though — they're still subject to most of the Act's conduct rules and can face discipline for violations.
If your business model is "in-house sales team plus subcontracted licensed electricians for install," expect both the sales team and the company itself to need registration, while the electrical subcontractor's own license may cover their piece.
What the Code of Conduct Prohibits
TDLR's rules (adopted under the authority in Texas Occupations Code Chapter 1806) spell out a code of conduct for registrants. Prohibited practices include:
- Making false or misleading statements about projected savings, energy production, or financing terms
- Misrepresenting an affiliation with a utility company, government agency, or other entity the homeowner might trust
- Soliciting at a residence that displays a "No Soliciting" sign
- Failing to provide the required contract disclosures in the format and language mandated by the rules
- Other deceptive or high-pressure sales tactics identified in the adopted rules
Penalties: Where the Real Risk Is
This is the part that should get a business owner's attention. Under the fully enforceable rules:
- Standard violations: up to $2,500 per violation, capped at $50,000 in aggregate.
- Violations involving a customer age 65 or older: the maximums double — up to $10,000 per violation, capped at $100,000 in aggregate.
- Additional remedies: TDLR can also order contract cancellation and a full refund to the affected customer, on top of any monetary penalty.
Because Texas has a large retiree population and solar sales frequently target homeowners in that demographic, the elevated senior penalty tier isn't a corner case — it's a live exposure for any residential solar sales operation. A single bad script used against several senior customers can add up fast under a $10,000-per-violation ceiling.
How to Prepare Before September 1, 2026
- Confirm your contract templates already reflect the 2025 rules. If you haven't updated your standard residential solar contract with the licensed-contractor disclosure, the five-business-day cancellation clause, and the lender-cancellation provision, that's overdue, not just upcoming.
- Identify everyone on your team who needs to register. Map your sales roster against the "solar salesperson" definition — commission-based door-to-door reps, call center closers, and referral-based sellers likely all qualify unless they hold their own electrical contractor license.
- Submit TDLR registration applications well before the deadline. TDLR made applications available ahead of September 1, 2026, specifically so retailers and salespeople wouldn't be scrambling. Given that operating without registration after the deadline is itself a violation, don't treat this as a same-week task.
- Audit your sales scripts and marketing materials against the prohibited-practices list. Savings claims and financing comparisons are the two areas most likely to draw scrutiny — make sure projections are substantiated and financing terms are disclosed clearly, not buried.
- Train your team on the "No Soliciting" sign rule specifically. It's an easy, mechanical compliance win: if a rep can be shown to have knocked past a posted sign, that's a straightforward violation regardless of what was said inside.
- Check whether your registration status needs to be verifiable. TDLR-regulated trades typically publish license/registration lookups; be prepared for customers or competitors to check.
The Bookkeeping Angle: Registration and Compliance Costs Are Real Line Items
Whatever TDLR ultimately sets as the registration fee, and whatever your business spends on updated contract templates, compliance training, or legal review to align sales scripts with the code of conduct, those are real business expenses that belong in your books — not absorbed as an untracked cost of doing business. If TDLR levies a penalty or orders a refund down the line, having clean, auditable records of your contracts, disclosures, and registration status is exactly what you'll want on hand to demonstrate good-faith compliance.
This is also a good moment to separate solar-specific regulatory costs (registration fees, TDLR-mandated training, compliance consulting) from general sales and marketing spend in your chart of accounts. That distinction makes it much easier to answer the question every solar retailer will eventually get asked by a lender, insurer, or the state: can you show exactly what you spent to comply, and when?
Keep Your Compliance Records as Clear as Your Contracts
Navigating a new licensing regime is easier when your financial records are just as transparent as the disclosures SB 1036 now requires you to give customers. Beancount.io provides plain-text accounting that gives you complete transparency and control over your financial data — no black boxes, no vendor lock-in. Get started for free and see why developers and finance professionals are switching to plain-text accounting.