What Does Texas’s New School Safety Rule Require of New and Renovated Buildings?
Texas has moved its school safety standards into a new rule and tied them to the construction cycle. For districts, architects and contractors, the security review is now a pre-occupancy step, and the state expects it to be certified.
It requires a security review before students occupy any newly constructed, acquired or substantially renovated instructional facility. 19 TAC §103.1215, effective September 1, 2026, carries forward Texas’s standards for exterior doors, glass, primary entrances and panic alerts, and from August 1, 2026 requires school systems to certify those reviews in Sentinel. Because the rule’s glass and door language is functional rather than tied to a test method, the performance basis still has to be written into the design documents.
The Texas Education Agency filed new 19 TAC §103.1215, School Safety Requirements, with the Secretary of State on August 3, 2026, and repealed the former §61.1031 at the same time. Both actions took effect September 1, 2026. The rule was proposed in the March 27, 2026 Texas Register (51 TexReg 1950) and adopted without changes to the proposed text. In a September 24, 2026 letter to school administrators, TEA summarized the change: the standards were moved from §61.1031 and extended under HB 33 to newly constructed, acquired and substantially renovated facilities.
For most of the substantive requirements, this is a relocation. TEA told one commenter that relocating provisions "does not alter substantive obligations." What is new is the link between the standards and the building project, and that link is what designers and contracting staff need to plan for.
What changed
According to the adoption notice, the rule implements HB 33 and HB 121 from the 89th Legislature (2025), along with HB 3 and SB 838 from 2023. HB 33 added Texas Education Code §37.1087, which requires a district that constructs, acquires, renovates or improves a facility to conduct a security review to determine whether the facility meets safety and security requirements. The Senate committee bill analysis describes the review as also identifying vulnerabilities in the event of an active shooter incident and describing strategies to mitigate each one. The act took effect September 1, 2025.
The new rule turns that statute into a schedule:
- Timing. Security reviews should be conducted as soon as practicable after a facility is constructed, acquired or renovated, and must occur before students occupy the building.
- Certification. Beginning August 1, 2026, school systems must certify in Sentinel, the system covered by TEA's required reporting rule, that the reviews have been conducted.
- Scope. The standards apply to all instructional facilities a school system owns, operates or leases, regardless of construction or lease date, and the new language confirms they apply to new, acquired and substantially renovated buildings.
- Definitions. The rule now states that "A perimeter fence does not constitute an exterior secured area."
- Responder documents. Electronic copies of exterior and interior door numbering site plans must go to 9-1-1 entities, emergency service districts, law enforcement and other first responders, who may conduct walk-throughs.
Enforcement also tightened. Companion rule §103.1219, also effective September 1, 2026, allows the Commissioner to assign a conservator when a district fails to comply with school safety requirements or fails to address issues from TEA monitoring, assessments or audits within one year.
The facility standards a review will test
The rule text requires access points that are secured by design, maintained to operate as intended and appropriately monitored. The provisions most relevant to construction documents are:
- Exterior doors. Doors, frames and their components must be built "of materials and in a manner that make them resistant to entry by intruders." Unless inside an exterior secured area, doors that are glass or contain glass must be "constructed or modified such that the glass cannot be easily broken," with forced entry-resistant film offered as an example. Exterior doors must stay closed, latched and locked, subject to listed exceptions, and must allow egress from inside.
- Glass near doors and at ground level. Windows adjacent to an exterior door that, if broken, would let someone reach in and open the door, and ground-level windows near exterior doors that would permit entry if broken, carry the same "cannot be easily broken" language unless they sit inside an exterior secured area.
- Primary entrances. Unless a secure vestibule is present, the primary entrance must let occupants see who is outside, provide a visitor check-in location and "feature a physical barrier that prevents unassisted access to the facility by a visitor."
- Exterior secured areas. Qualifying enclosures use a fence or wall at least 6 feet high with features that prevent easy scaling, or at least 8 feet high, with locked gates fitted with emergency egress hardware.
- Door numbering. Every exterior door location except the primary entrance carries alphanumeric characters at least four inches high on the interior and exterior.
- Communications. Law enforcement and emergency responder two-way radios must function "within most portions of the building(s)," and the panic alert system must, among other features, lock remotely lockable exterior doors automatically when triggered.
Operating requirements follow the building after turnover: a board policy requiring at least weekly exterior door inspections during school hours, and maintenance checks at least twice a year to confirm that the required facility components function as required.
Where the rule leaves the performance decision
Phrases such as "resistant to entry by intruders" and "cannot be easily broken" state an outcome without naming a test method, a tool set or a duration. That leaves the reviewer, the designer and the owner to agree on what passes. Certanet has made the same point about forced-entry protection in building codes generally: without a stated threat and a stated delay, two compliant buildings can perform very differently.
Comments on the proposal show the pressure points. The Texas Association of Architects asked for language letting districts and charter schools claim and document good cause exceptions under TEC §37.353. TEA declined, responding that "Good cause exceptions related to facility safety are not equivalent to compliance with school safety requirements." Design teams should not assume an exception will cover a shortfall found at the review.
TEA's fiscal note anticipates no additional cost for the modifications, though the preamble acknowledges the requirements impose costs on districts and charter schools, which grants may offset. Neither statement prices the doors, frames, glazing and barriers each project needs.
What districts, designers and contractors should do now
- Schedule the review as a closeout milestone. Because it must precede student occupancy, the review belongs in the project schedule alongside the certificate of occupancy, with time to correct findings.
- Write measurable criteria into the specifications. For each door, frame, glazed opening and entrance barrier, state the intended resistance, the test standard or acceptance evidence and the tested configuration, as discussed in Certanet's guidance on procurement language for secure facilities.
- Treat openings as one system. A resistant door in a weak frame, or a filmed lite beside unprotected sidelights, fails at the weakest point.
- Make door numbering and site plans deliverables. Sign heights, sequence, true-north plans and electronic files for responders can all be assigned to the design team and verified at closeout.
- Coordinate alert and locking systems early. Automatic locking on a panic alert ties hardware, access control and communications together, which is easiest to resolve before the hardware schedule is final.
- Apply the same discipline to renovations and acquisitions. Acquired buildings trigger the review too, so condition assessments should include the facility standards.
Texas has not created a new protection level. It has made the existing standards a gate that every new, acquired or substantially renovated school building must pass before students arrive. Its value will depend on how precisely each project defines what "resistant" and "cannot be easily broken" mean.
Recommended citation
Certanet Research, “What Does Texas’s New School Safety Rule Require of New and Renovated Buildings?” Certanet, October 22, 2026, https://certanet.com/articles/texas-school-safety-rule-security-reviews-new-construction.html.