TL;DR

Texas real estate licenses operate on a two-year renewal cycle under Texas Occupations Code §1101.455, with 18 hours of continuing education required for each renewal under 22 TAC §535.92. The CE breakdown differs between sales agents and brokers. Sales agents must complete 4 hours of Legal Update I, 4 hours of Legal Update II, 3 hours of contract-related coursework, and 7 hours of elective CE. Effective January 1, 2026 (SB 1968), active brokers renewing must complete 4 hours of Legal Update I, 4 hours of Legal Update II, the 6-hour Broker Responsibility Course, 3 hours of contract-related coursework, and 1 hour of elective CE — regardless of whether the broker sponsors sales agents. First-time license holders face additional requirements — 98 hours of Salesperson Apprentice Education within the first 24 months — and late, inactive, or expired licenses involve distinct reactivation pathways. The framework parallels the Florida real estate license renewal and CE regime with comparable structure but different specifics.

The two-year renewal cycle

Texas Occupations Code §1101.455 establishes the two-year renewal cycle for sales agents and brokers. The license expires on the last day of the month two years after issuance (or the prior renewal date). A renewal application filed before expiration with proof of completed CE hours produces a renewed license effective the day after the prior expiration. Renewal applications filed within 6 months after expiration are permitted on payment of late-renewal fees; renewal applications filed more than 6 months but less than 24 months after expiration require additional requirements; renewal beyond 24 months is not permitted — the license holder must restart the licensing process.

The renewal application is submitted online through the TREC license services portal. Required information includes the CE completion certificates (TREC verifies CE through its provider system), the renewal fee, and confirmation that the license holder meets ongoing requirements including character and fitness. Errors and omissions insurance is not required for individual license holders under Texas law — unlike some states that mandate E&O — though many brokerages require sponsored associates to carry E&O.

The 18-hour CE breakdown

22 TAC §535.92 requires 18 hours of continuing education for each two-year renewal. The breakdown differs for sales agents and active brokers.

For sales agents and non-broker license holders, the 18 hours consist of: 4 hours Legal Update I, 4 hours Legal Update II, 3 hours contract-related coursework, and 7 hours of elective CE. For active brokers renewing on or after January 1, 2026, the 18 hours consist of: 4 hours Legal Update I, 4 hours Legal Update II, the 6-hour Broker Responsibility Course, 3 hours contract-related coursework, and 1 hour of elective CE.

Legal Update I focuses on agency law, contract law, and ethical practice updates. Legal Update II focuses on Texas-specific compliance topics — TRELA changes, TREC rule revisions, and disciplinary trends. Both Legal Update courses are mandatory for both sales agents and brokers; substitution of other courses for the Legal Update content is not permitted. The contract-related 3-hour requirement is also fixed; the elective hours allow license holders to pursue topics matching their practice — commercial, residential, property management, investment, broker management, etc. TREC updates Legal Update I and Legal Update II annually to cover recent statutory, regulatory, and case-law developments.

The Broker Responsibility Course — SB 1968

SB 1968 (2023, Ch. 853) added the Broker Responsibility Course as a mandatory CE component for brokers. Effective January 1, 2026, every broker applicant and every broker renewal applicant must complete the 6-hour Broker Responsibility Course — regardless of whether the broker intends to sponsor sales agents. This is a substantive change from the earlier requirement that applied only to brokers who actively supervised sponsored associates; under the current rule, the course is required for all brokers, sponsoring or not. Delegated supervisors are also subject to the course requirement.

The course covers broker supervision of sponsored associates, trust-fund management, advertising compliance, and the broker's role in transaction oversight. The Broker Responsibility Course occupies 6 of the 18 required hours for broker renewal — combined with 4 hours Legal Update I, 4 hours Legal Update II, 3 hours contract-related coursework, and 1 hour elective CE for the full 18-hour total.

SB 1968's effective date matters for renewal planning. Brokers whose two-year renewal cycle ends on or after January 1, 2026 must include the Broker Responsibility Course in the renewal CE. Inactive brokers who later reactivate may need to complete the course as part of reactivation; the broker should confirm the current rule with TREC before relying on grandfather treatment.

First-time license — SAE requirements

First-time Texas sales agent license holders face Salesperson Apprentice Education (SAE) requirements at the first renewal under 22 TAC §535.55. The framework is best understood by total qualifying hours rather than incremental hours. At the first renewal, a sales agent must have a total of 270 hours of approved qualifying real estate education, plus 4 hours Legal Update I and 4 hours Legal Update II. A sales agent who originally completed the standard 180 pre-license qualifying hours must therefore complete an additional 90 SAE qualifying hours to reach the 270-hour total — commonly marketed as a 98-hour SAE package that bundles the 90 qualifying hours with the 8 hours of Legal Update I and II.

Legal Update I and II are separate from — not included within — the qualifying/SAE hours. The first renewal therefore requires both the qualifying-hour total (270 total) and the Legal Update hours (4 + 4 = 8). Failure to meet either requirement at first renewal causes the license to lapse and require reactivation. For broker license holders, the SAE structure does not apply (brokers complete different qualifying education before broker licensure), and the standard 18-hour CE applies from the first renewal.

Inactive, expired, and reactivation pathways

An active license holder may voluntarily place the license on inactive status through TREC. Inactive status preserves the license but suspends the right to engage in real estate brokerage activity. CE is not required for inactive license holders, but reactivation requires completing any CE that would have been required during the inactive period. Inactive status can be maintained indefinitely subject to renewal payments.

Late renewal pathways follow TREC's post-expiration timeline. Up to six months after expiration, late renewal is available on payment of late-renewal fees. After six months and up to two years past expiration, the license holder cannot renew but may apply for reinstatement, with additional requirements including current CE. After two years past expiration, the license is permanently expired and the former license holder must reapply, complete current qualifying education, and pass the licensing exam from scratch.

Revoked or surrendered licenses follow a different pathway. A license revoked through TREC discipline cannot be casually reinstated — the former license holder must petition TREC for reinstatement and demonstrate that the underlying disciplinary basis has been resolved. Surrendered licenses (voluntary surrender in lieu of discipline) similarly require petition for reinstatement.

Cross-state comparison with Florida

The Texas renewal framework parallels the structure of the Florida real estate license renewal regime — see our Florida real estate license renewal and continuing education guide for the FL framework. Both states use multi-year renewal cycles with mandatory CE; both impose specific course requirements within the CE total; both provide reactivation pathways for late and expired licenses.

The substantive differences matter for licensees who hold both state licenses. Florida's two-year CE total is 14 hours (3 Core Law + 3 Ethics & Business Practices + 8 specialty), and the first renewal requires the 45-hour post-license course (FREC I). Texas's 18 hours plus the new Broker Responsibility Course requirement is structurally different. A multi-state licensee must complete each state's specific CE separately — credit transfer between states is generally not available.

Broker supervision overlay

The broker's CE compliance and supervisory duty are connected. The Broker Responsibility Course explicitly addresses the broker's obligation to monitor sponsored associates' CE compliance — see our Texas broker supervision and trust-fund rules guide for the full broker oversight framework under 22 TAC §535.2. A broker whose sponsored associates fall out of CE compliance can face supervisory discipline even if the broker's own CE is current. TREC enforcement increasingly targets broker-side supervision failures rather than individual associate-level violations.

Frequently Asked Questions

Can CE hours be completed online?
Yes. Most TREC-approved CE courses are available in online formats. The course provider must be TREC-approved, and the course must include verifiable completion mechanisms (typically a final assessment and time-tracking). License holders should verify the course's TREC approval status before enrolling — non-approved courses do not satisfy the CE requirement.
Can a license holder complete more than 18 hours of CE during a cycle and carry the excess forward?
No. CE hours are credited to the renewal cycle in which they are completed. Excess hours do not roll forward to the next cycle. License holders who complete CE early in a cycle do not get a credit toward the next cycle's requirement. Most license holders complete CE during the second year of the cycle to maximize relevance of the Legal Update content.
Does the Broker Responsibility Course apply to all brokers or only sponsoring brokers?
SB 1968 applies the requirement to every broker applicant and every broker renewal applicant effective January 1, 2026 — regardless of whether the broker sponsors sales agents. The course is particularly relevant for sponsoring brokers and delegated supervisors, but the statutory requirement reaches all active brokers. Inactive brokers may need to complete the course as part of reactivation; the broker should confirm the current rule before relying on any exemption.
What happens if a license holder completes CE just before expiration but the certificate arrives after expiration?
TREC credits CE based on the date of course completion, not the date the certificate is delivered or processed. A license holder who completes a course on the last day of the renewal cycle has timely-completed CE even if the provider's processing takes additional days. TREC's online verification system typically reflects completion within a few business days of the provider's submission.
Are E&O insurance requirements imposed by Texas law?
No. Texas does not mandate errors and omissions insurance for individual real estate license holders, unlike some states. Many Texas brokerages require sponsored associates to carry E&O as a condition of sponsorship, but this is a private arrangement, not a TRELA requirement. The license itself can be renewed without E&O documentation.
How does SAE differ from standard CE for first-time license holders?
SAE (Salesperson Apprentice Education) is the additional qualifying education required at first renewal — totaling 270 qualifying hours plus 4 hours Legal Update I and 4 hours Legal Update II. A sales agent who entered with the standard 180 qualifying hours typically completes 90 additional SAE qualifying hours plus 8 hours of Legal Update for the first renewal, frequently sold as a 98-hour package. SAE covers specific topic areas required by 22 TAC §535.55 — agency, contract, finance, property management, etc. After the first renewal, the license holder transitions to the standard 18-hour CE framework (4 + 4 + 3 + 7 for sales agents).

Bottom Line

Texas real estate licenses operate on a two-year renewal cycle requiring 18 hours of CE with breakdown differing by license type. Sales agents complete 4 hours Legal Update I + 4 hours Legal Update II + 3 hours contract-related + 7 hours elective. Effective January 1, 2026 (SB 1968), every broker — sponsoring or not — completes 4 hours Legal Update I + 4 hours Legal Update II + the 6-hour Broker Responsibility Course + 3 hours contract-related + 1 hour elective. First-time sales agent license holders must reach 270 total qualifying hours (typically 90 additional SAE hours after the 180-hour pre-license course) plus Legal Update I and II for the first renewal. Late and inactive licenses follow distinct reactivation pathways with hard limits at 24 months past expiration. The renewal framework parallels — but is structurally different from — the Florida renewal regime, and multi-state licensees must complete each state's CE separately. For the broker's supervisory duty over sponsored associate CE compliance, see our Texas broker supervision and trust-fund rules guide. For the full exam blueprint and the other Texas-specific topics you'll need to know, see our Texas real estate exam complete guide.

Source: Tex. Occ. Code §1101.455 — License Renewal · 22 TAC §535.92 — Continuing Education · Texas Real Estate Commission