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APA Texas Chapter Update

2025 was a busy year for the APA Texas Chapter (APA TXC).  As Meghan noted in the last APA newsletter, we have been actively engaging with the Texas Department of Licensing and Regulation (TDLR) regarding major changes to ownership verification requirements, the rollout of new forms, and the growing administrative burden on Registered Accessibility Specialists (RASs).

At the APA Conference in January, TDLR held an information session on the new administrative requirements called "Behind the Paperwork" and one panel discussion to answer specific questions from the RASs in attendance.  We are thankful to everyone who spoke out at the Q&A session so TLDR could have a better understanding on what we are experiencing on a daily basis.

Headshot of smiling woman with brown hair and glasses

After the conference, TDLR responded with the following information:

"TDLR is working with the Procedures workgroup, that includes an active RAS (and APA member), for forms updates, help sheets, videos, etc.  The team is working on additional documents that were requested at the conference, but they take time and we are trying to catch up since working the conference, but we will make every effort to try to meet your requested deadline.
Clarification on projects registered before September 7, 2025:
Projects registered prior to September 7th 2025 (regardless of who registered the project) do not require the input of the CAD number into the TABS project information unless the project information needs to be updated in TABS (because of programming).
  • This does not exempt the requirement that TDLR forms must be completed in full – including OAD and received project registration forms received between September 2023 and August 2025 as those have required fields.
  • If the project owner contact information reflects an owning entity and the representative signing documents is an employee of that entity an OAD is not required to be obtained.
  • If the project owner contact information reflects an owning entity and the representative signing documents is NOT or does not appear to be an employee of the owning entity an complete OAD (including CAD number) was required prior to September 2025. If a complete OAD form, that predates September 2025, is not on file in TABS an LLO form is required.
  • TDLR will verify owner information prior to processing transfer request that come to TDLR and if ownership information is found to be inaccurate in the system then the system will be updated.  Should the owner information be updated previous forms from the inaccurate owner will be void."
We’ll continue to keep members updated as we receive information or responses from TDLR. In the meantime, you can:
  • Share your experiences
    • If you have specific examples of delays, confusion, or issues caused by the LLO/OAD rollout and ownership requirements, please send them to the APA Texas Chapter leadership or post in the APA forum.
  • Document your time and issues
    • Track how much time you are spending on ownership verification tasks and related emails. This data may help demonstrate the actual burden compared to the “11% inefficiency” cited by TDLR.
  • Contact TDLR to share your concerns
  • Participate in discussions and training
    • Join the APA forum conversations and attend Texas Chapter meetings.
If you have questions, comments, or want to get more involved in advocacy efforts, please reach out to the APA Texas Chapter leadership.  I would love to get more Texas Chapter members involved throughout the year.
Our first chapter leadership meeting is March 9th.  If you have any ideas for events or presentation topics this year, please reach out to one of the chapter leaders before that date.
We’ll continue to push for a process that is fair, efficient, and focused on what matters most: accessible buildings and environments for Texans.

Corey Credeur, 2026 APA Texas Chapter President

March 2026