We Need Your Help: Act Now on Proposed Texas ID Requirement Changes

• By: TIADA Compliance
• On: 12/18/2025 11:29:44
• In: Texas Posts
• Comments: 0

The Texas Department of Motor Vehicles (TxDMV) is proposing new rules that would permanently change what identification is required to register a vehicle in Texas. These proposed changes raise serious concerns for independent dealers, employees, and customers—and your personal story is one of the most effective tools to influence the outcome.

TIADA has been meeting with stakeholders, building coalitions, and speaking with government officials since before these rules were issued. While we can provide technical and legal guidance, only you can share your personal experiences. Regulators need to hear directly from dealers about how these rules impact real businesses, employees, and customers across Texas.

If you do not submit a comment, your perspective may not be part of the record. Even a short letter can make a difference. Click here for help and instructions on submitting your comment.

Deadline to submit comments: 5:00 p.m. CST on January 5, 2026
 

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What Is Changing and Why It Matters

TxDMV has proposed amendments to 43 Texas Administrative Code §§217.22, 217.26, 217.28, and 217.29, relating to personal identification requirements for vehicle registration under Transportation Code §502.040.

Under the proposal, TxDMV would give legal authority to the guidance that was recently placed to restrict the types of identification that can be used to register a vehicle, including requirements intended to verify lawful presence.

TxDMV's stated reasons for the proposal include:

• Ensuring applicants provide valid identification
• Verifying applicants are legally eligible to reside in Texas
• Preventing fraud in vehicle registration

Dealer concerns focus on unintended consequences, including:

• Sales delays caused by DPS backlogs when customers must obtain new or replacement identification and face long appointment wait times
• Customers who are clearly not undocumented being unable to complete transactions
• Dealers being expected to review and interpret immigration-related documents without the training or expertise to do so, placing them in roles they were never previously required—or legally expected—to assume

These concerns are compounded by federal fair-lending laws. In October 2023, the Consumer Financial Protection Bureau (CFPB) and the U.S. Department of Justice issued guidance warning that creditors may not deny credit solely based on immigration status when an applicant is otherwise qualified. Overly broad reliance on immigration status can expose businesses to claims of unlawful discrimination.

Full rule proposal:
https://www.txdmv.gov/sites/default/files/body-files/Chap_217_Non-Emergency_-_Prop.pdf Where and How to Submit Your Comment

Email: rules@txdmv.gov

Mail:
Laura Moriaty
General Counsel
Texas Department of Motor Vehicles
4000 Jackson Avenue
Austin, TX 78731

Tip: Sending both a mailed and emailed copy ensures it is received.

What to Include in Your Letter
You do not need to address every issue. Focus on what you know best—your experience.

1. Your Dealership's Story

• How your business started and grew
• Family or personal involvement
• Any experiences related to the new ID requirements

2. Impact of the Change

• How the rules affect operations, employees, and customers
• Any unintended consequences you've encountered
• Concerns about reviewing documents outside your expertise

3. Your Investment in Texas

• Employees, locations, growth, loans provided
• Note that investments were made under prior rules that did not require citizenship inquiries

 

4. Your Role in the Community

• Jobs supported, local economic impact, charitable involvement

Make One Clear Ask
End your letter with one clear request:

• Request a safe harbor, such as grandfathering existing loans or exempting vehicles with active liens
• Ask that the rule be returned to its prior form
• Or request another outcome you believe is appropriate

One clear ask is more effective than multiple.
Sample Opening Language (Optional)
Thank you for the opportunity to provide comments regarding the Texas Department of Motor Vehicles' proposed amendments to 43 Texas Administrative Code §§217.22, 217.26, 217.28, and 217.29, relating to personal identification requirements for vehicle registration under Transportation Code §502.040. I write to share how these changes affect my business, employees, and customers, and to highlight unintended consequences that should be considered before the rules are finalized.

Final Reminder
Every comment becomes part of the official record. Regulators may never hear from another dealer exactly like you—but they will read what you submit. Your experience can shape how these rules are finalized.

Support Dealer Advocacy Through INDEPAC
In addition to submitting comments, PAC contributions help support legislators who understand and advocate for independent automobile dealers. We rely on these relationships to advance policies that benefit our industry, and showing your support helps maintain strong, mutually beneficial connections with these friends of independent dealers.

Consider contributing to INDEPAC

• Online: Through the TIADA website
• By Mail or In-Person:
  INDEPAC
  9951 Anderson Mill Rd, Suite 101
  Austin, TX 78729

Every comment and contribution strengthens our ability to advocate on your behalf. If this impacts your business help be part of the solution by writing a letter, sending a check, or recruiting a member for the association as the more engaged dealers are the more likely we are to secure a favorable outcome.