SB 2610 Compliance for Texas Businesses
Avoid Punitive Damages. Strengthen Your Cybersecurity. Comply by Sept 1.
If your business has fewer than 250 employees and handles personal data, Texas SB 2610 now requires you to maintain a documented cybersecurity program. Without it, you risk exposure to lawsuits and punitive damages.
AVATAR partners with small and mid-sized Texas businesses to develop compliant, defensible cybersecurity programs—backed by industry expertise and aligned with legal requirements. We translate complex regulations into clear, actionable protections for your business.
Why SB 2610 Should Be on Your Radar
The Stakes Are High
Starting September 1, 2025, if you’re a Texas business with fewer than 250 employees and handle personal data, you’re legally at risk. SB 2610 introduces a game-changing liability shift. If your business isn’t compliant—and a breach occurs—you could face punitive damages, even if the breach wasn’t your fault.
Your Only Defense: Compliance
The law gives you a shield—but only if you use it. To qualify for legal protection, your business must have a documented cybersecurity program that aligns with recognized security frameworks under SB 2610.
Resources: Know the Law Behind HB150 & SB2610
HB 150 reinforces these protections by requiring the Texas Attorney General to publish an official list of recognized cybersecurity frameworks. That means Texas businesses now have a clear, authoritative path to follow—so there’s no guesswork in achieving compliance and securing legal protection under SB 2610.
Together, HB 150 and SB 2610 form a powerful legal incentive for Texas businesses to adopt and document strong cybersecurity practices—before it’s too late. See the full text of both bills below.
What Does Compliance Look Like?
Compliance Framework by Business SizeBusiness Size
Required Framework
Key Actions
1 – 19
Password policy + training
20 – 99
CIS Controls IG1
100 – 249
NIST Cybersecurity Framework 2.0
How AVATAR Gets You Compliant
3-Step Process:
- Precision Assessment – Identify where you stand
- Targeted Implementation – Apply only what’s needed
- Ongoing Qualification – Maintain compliance over time
What SB 2610 Means for Your Industry
- Even if you’re already HIPAA-compliant, SB 2610 introduces new civil liability risks for small practices, clinics, and independent providers. If you store PHI or patient information, you must show active cybersecurity training and a documented security program—not just HIPAA paperwork.
- Don’t assume you’re covered. SB 2610 is separate, and it requires state-specific proof of protection.
- Client confidentiality is a legal and ethical responsibility—but under SB 2610, it’s also a civil liability. If your firm experiences a data breach and doesn’t have a documented cybersecurity framework, you can face punitive damages in addition to legal fees.
- AVATAR helps law firms align with CIS or NIST quickly and affordably—no unnecessary tech, just legal-grade protection.
- If you collect customer names, emails, payment info, or shipping data, you’re handling regulated personal information. Under SB 2610, Texas retailers must implement baseline cybersecurity controls like secure configurations, patching, and password policies to avoid legal exposure.
- We’ll help you meet requirements without disrupting operations or customer experience.
- You already handle sensitive financial data—but being “regulated” isn’t the same as being SB 2610-compliant. This law offers civil “safe harbor,” but only if your cybersecurity program is formally documented and maintained.
- We’ll align you with NIST quickly and validate what counts toward compliance—no duplication, no confusion.
- Construction businesses often overlook data risk—but bid data, vendor files, and HR records all count as protected information. SB 2610 applies to general contractors, subcontractors, and builders—especially those storing project documents or using cloud-based systems.
- Let AVATAR map your tools and workflows to the right controls—and shield you from unnecessary liability.
- Even nonprofits face risk under SB 2610. Donor lists, payment platforms, event RSVPs, and volunteer records all include personal data. If your nonprofit experiences a breach without a cybersecurity program, you could face crippling punitive damages—on top of the reputational fallout.
- Let us help you protect your mission and remain funder-ready with the right safeguards in place.
SB 2610 applies to all Texas businesses that collect or store personal data—no matter your industry. Not seeing your category listed? Don’t worry. We’ll help you:
- Identify what data you store
- Determine which cybersecurity framework applies to you
- Build a plan to meet the September 1st deadline
Compliant vs. Non-Compliant Table
Risk Type
Compliant
Non-Compliant
Protected
Exposed
Legal Standing
Strong
At Risk
Civil Liability
Limited
Non-Compliant
Customer Trust
Maintained
Damaged
FAQs: SB 2610 Compliance
SB 2610 requires Texas businesses with under 250 employees to implement a documented cybersecurity program to avoid punitive damages in the event of a data breach. HB 150 mandates additional breach notification responsibilities. If you’re not compliant, you’re exposed to lawsuits—even if the breach wasn’t your fault.
Both laws go into effect September 1, 2025. That means businesses must act now to ensure proper security frameworks and breach protocols are in place before the deadline.
SB 2610 applies to any Texas business with fewer than 250 employees that collects, uses, stores, or transmits personal data. If that’s you, the law requires you to implement a formal cybersecurity program—or face legal risk.
To comply, your business must have a written cybersecurity program that aligns with industry standards—such as the NIST Cybersecurity Framework or CIS Controls. AVATAR helps tailor these programs to your size, risk level, and industry.
If you’re not compliant and a data breach occurs, you can be held liable for punitive damages, even if the incident was beyond your control. Compliance is your only legal shield under SB 2610.
HB 150 expands data breach notification requirements. You must notify the Texas Attorney General and affected consumers within 30 days of a breach—down from the previous 60-day window. Delay or failure to notify can result in serious penalties.
Any information that can identify an individual—such as names, addresses, social security numbers, health or financial data—puts you in scope. If you collect customer or employee data, you’re likely subject to these laws.
Not complying is far more expensive. AVATAR offers tiered compliance packages that align with your business size and needs, starting with an affordable baseline assessment and scaling up as needed. Our goal is risk reduction—without breaking your budget.
Unfortunately, SB 2610 requires a formalized, documented cybersecurity program, not just tools. AVATAR helps you go beyond basic IT hygiene to meet the law’s requirements and protect your business legally and operationally.
No. Most cyber insurance policies now require proof of a formal cybersecurity program—and many insurers deny coverage or reduce payouts if you’re not compliant with laws like SB 2610. Without documented protections in place, your policy may not help when you need it most. Compliance isn’t just legal protection—it’s how you keep your insurance valid.
Get Protected Before the Deadline
SB 2610 takes effect September 1. If you’re not compliant, you’re vulnerable. Let’s change that.
- Trusted by Texas small and mid-sized businesses
- Helping Texas businesses under 250 employees get compliant—fast
- Cybersecurity compliance for small & mid-market Texas companies
- Compliance without complexity
- Clear path to protection
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