HB103 FREQUENTLY ASKED QUESTIONS

The statutory authority for the HB 103 Bond, Tax, and Project Database can be found in Texas Government Code Chapter 403, Subchapter V, consisting of Sections 403.701 to 403.705 (as added by Acts 2025, 89th Leg., R.S., Ch. 711 (H.B. 103), Sec. 1.)

Yes. Currently, an entity that is subject to the reporting requirements of HB 103 must submit the report(s) required by that legislation to the Comptroller’s office, regardless of whether it has also reported the information described under HB 3526 or SB 843 to another state agency. The Comptroller recognizes that this may result in an entity reporting the same or similar information to more than one office and regrets any inconvenience. Please be assured that CPA is in the process of coordinating with those agencies to examine various avenues for streamlining these reporting requirements and remains committed to working with affected taxing units to determine how best to resolve this issue while striving to make this information available to the public in a timely manner.

The Comptroller is required to develop and maintain a database containing current and historical information on taxes imposed and bonds issued. The database will include:

• Ballot language for bonds
• Projected tax rates for debt service
• Estimated minimum annual debt service requirements resulting from the issuance of a bond
• Election results for bond approvals
• Lists of funded projects and accounting for bond proceeds
• Tax rate changes resulting from issued bonds
• Election results for tax rate elections
• Proposed or approved maintenance tax rates for school districts
• Ballot language for school district maintenance taxes

HB 103 reporting is in addition to the requirements of HB1378, Local Government Debt Reporting.

HB 103 applies to taxing units that meet the definition set forth in Section 1.04 of the Tax Code, which reads: "Taxing unit" means a county, an incorporated city or town (including a home-rule city), a school district, a special district or authority (including a junior college district, a hospital district, a district created by or pursuant to the Water Code, a mosquito control district, a fire prevention district, or a noxious weed control district), or any other political unit of this state, whether created by or pursuant to the constitution or a local, special, or general law, that is authorized to impose and is imposing ad valorem taxes on property even if the governing body of another political unit determines the tax rate for the unit or otherwise governs its affairs."

To report into the database, the local government must:

• Meet the requirements of Tax Code, Section 1.04(12);
• Be a qualified taxing unit with a bond that may be paid from or secured, in whole or in part by ad valorem taxes; and
• Have a "voter-approval tax rate," which means the voter-approval tax rate for a taxing unit calculated under Chapter 26 (Tax Code section 403.701).

No. There is no reporting requirement under HB103, if an entity is not a taxing unit.

All required data identified in subsections (b)(1) through (b)(3) for tax years 2015 through 2025.

HB 103 requires entities to report bonds that are proposed or issued by a taxing unit (as that term is defined in Sec. 1.04 of the Tax Code) and which are to be repaid in whole or in part through the levy, pledge, assessment, or collection of ad valorem taxes. Reporting entities should consult an attorney if they have any questions about the application or requirements of HB 103.

General Obligation (GO) bonds, revenue bonds and Public Improvement District (PID) bonds could all be fair game, so long as they meet the criteria described above.

Also, Permanent School Fund (PSF) bonds wouldn’t be secured with ad valorem taxes since they have a constitutionally dedicated fund.

As for certificates of obligation (COs) or other alternative debt instruments, the intent of HB103 is not meant to include COs or other alternative debt instruments into this program. Of note during the 89th Regular legislative session, language describing “bonds and other debt obligations” was removed from the introduced version of HB 103 and replaced with just “bonds.”

While “revenue bonds” typically generate revenue from tolls and fees, they can use ad valorem taxes as one of its revenue streams to pay such a bond. As long as the taxing unit is a qualified taxing as identified in Tax Code Section1.04(12); has a bond that may be paid from or secured, in whole or in part by ad valorem taxes; and has a “voter-approval tax rate” then should be reported. Such instances of reporting a “revenue bond” are to be determined by the taxing unit if the elements are met.

For the purposes of HB 103 reporting, the voter-approval tax rate means the voter-approval tax rate for a taxing unit calculated Under Chapter 26 of the Tax Code.

As a general rule, no. However, in the unforeseen scenario, a loan is to be reported only if the local government (a) gets “voter approval” as required by statute, (b) the loans are secured with bond proceeds, and (c) they are payable with ad valorem taxes. In such cases, the bonds must be reported. If you have any questions about this, you should seek advice from your attorney.

No.

If the bond was approved in 2015 or later, then yes you will need to make a submission. If the bond was approved before 2015 then you do not need to submit a report.

No.

No. The bill is about bonds that are connected to and paid for by taxes. This is not about tax rates solely or taxes being used for some other local government program.

If the taxing unit did approve refunding a bond within the last 10 years, they would proceed to fill out the form as normal.

If the taxing unit did not approve refunding a bond, then they would simply provide the I&S voter approved tax rates for the year of issuance.

Beginning in 2026:

• May elections: Reports due by August 7 of the same year
• November elections: Reports due by August 7 of the following year

For example:

• May 2026 election → due August 7, 2026
• November 2026 election → due August 7, 2027

Local governments may begin entering their historical bond data starting November 14, 2025.

All historical bond data must be submitted by January 1, 2026.

Data should be submitted through the Comptroller’s website (once available)

An election held in November 2025 that occurs during the 2025 tax year (i.e., the 2025 calendar year) should be included in that historical reporting tool.

Yes. The public will be able to sort, search, and view all submitted reports on the Comptroller’s website.

HB 103 Step-by-Step Filing Instructions are available online and may provide answers to your questions, or you can contact the Comptroller’s Transparency Team:

• Transparency Hotline: 844-519-5676
• Email: transparency@cpa.texas.gov