Texas Ban-the-Box (HB 2466)

Effective September 1, 2025, HB 2466 restricts covered employers from asking about an applicant's criminal historyuntil the applicant is otherwise qualified — generally once they have been interviewed or given a conditional offer. This reverses Texas's prior "ask anytime" posture.

The law is commonly reported to reach public employers and private employers with 15+ employees, with exceptions for roles in law enforcement, health care, child care, and financial services. Because the threshold, covered employers, and exceptions are still being interpreted, confirm the current details before finalizing your process.

HB 2466 changes the timingof the question — it does not replace the federal Fair Credit Reporting Act process for running a background check (disclosure, authorization, and the two-step adverse-action sequence). Texas still has no state ICRAA-style law, and it limits negligent-hiring liability based solely on a criminal record (Tex. Civ. Prac. & Rem. Code ch. 142).

Remove criminal-history questions from the initial application (unless an exception applies), move the inquiry to after the interview/conditional offer, train recruiters on the new timing, and keep hiring decisions job-related and consistent.