What HB 700 Requires
Texas HB 700 took effect September 1, 2025 as a commercial financing disclosure and registration law reaching brokers and providers, MCA transactions included. The registration piece is the part that carries the hard deadline: brokers and providers have until December 31, 2026 to complete registration with the state. That is a real compliance action item with a fixed date, not an open-ended future requirement.
No De Minimis Exemption, Unlike Most States on This List
Of the eleven states currently regulating commercial financing disclosure, most exempt a broker or provider who completes fewer than five transactions in a 12-month period. Texas HB 700 does not. Alongside Louisiana, it is one of only two states in this research with no de minimis exemption at all, by entity type or dollar amount. A broker doing a handful of Texas deals a year cannot rely on low volume to sidestep registration the way they might in California, Connecticut, or several other states on this list.
The Enforcement Number: $10,000 Per Violation
The Office of Consumer Credit Commissioner, Texas's enforcement agency for this law, can assess penalties up to $10,000 per violation. Run that against a real book of business: a broker who ran multiple unregistered Texas transactions before the deadline is not looking at one flat fine, but a per-violation number that scales with volume. That is a meaningfully different risk profile than a state where the worst-case penalty is a single fixed fee.
Registration vs Disclosure: Two Separate Obligations
HB 700 sits inside the same "commercial financing disclosure law" category as the other ten states on the broader tracker, but registration is the specific piece with the near-term deadline. Disclosure requirements govern what you tell a merchant about the cost of financing before a deal closes. Registration governs whether you are allowed to operate as a broker or provider in Texas at all. HB 700 requires both, and the December 31, 2026 date applies specifically to registration, the action item that needs a state filing completed by a fixed calendar date, not an ongoing documentation practice you can phase in gradually.
A Practical Checklist Before the Deadline
- Confirm whether your business, or the ISO relationships you work through, currently closes any deals with Texas-based merchants.
- If yes, start the registration process well before December 31, 2026. State registration processes are rarely instant, and starting in the final weeks of the deadline year is a real risk.
- Confirm your Texas disclosure documents already meet the law's requirements, separate from the registration filing itself.
- Do not rely on transaction volume as an exemption. HB 700 has none.
- If you work with an outsourced calling or appointment vendor for Texas outreach, confirm they understand this is a registration requirement on the broker or provider, not something a vendor's own compliance covers on your behalf.
What this means for you
- Texas HB 700 (effective Sept. 1, 2025) requires broker and provider registration by December 31, 2026, with no de minimis exemption for low-volume brokers.
- The Office of Consumer Credit Commissioner can enforce violations up to $10,000 each, a per-violation number that scales with how many unregistered transactions occurred.
- Texas and Louisiana are the only two states in this research with no de minimis exemption at all. Low transaction volume is not a shield in either state.
Sources
The external data in this guide draws on the sources below. Figures described in the text as estimates or industry triangulations are directional and are not attributed to a single dataset.
- Venable LLP, state commercial financing disclosure laws (March 2026)
- Alston Consumer Finance, commercial financing disclosure requirements and exemptions