House Bill 1522
Questions and (some semblance of) Answers.
Adapted from the Texas Municipal League's discussion, originally found HERE.
H.B. 1522 amends the Open Meetings Act by changing two distinct requirements – the meeting notice period and budget-related postings.
Meeting Notice Period
Beginning September 1, 2025 (ESDs) will no longer be required to post notices 72 hours before the scheduled meeting time. Instead, they will be required to post notices at least three business days before the scheduled date of the meeting.
This new requirement has raised questions about how to calculate a three-business-day period. Although the recent changes to the Act do not provide a specific method, it’s likely attorneys will refer to the Code Construction Act (Government Code, Section 311.014) as well as case law and attorney general opinions for guidance. The Code Construction Act, which provides rules for interpreting and construing statutes when they are unclear, states that when calculating a time period not otherwise defined, one should exclude the first day and include the last day in their count.
Using this interpretation, a notice should most likely be posted on a Friday in order to hold a meeting the following Thursday. Under the Code Construction Act, Friday (the first day) does not count towards the three business days, but Monday, Tuesday, and Wednesday count, with Wednesday being the third business day (and last day) before the scheduled date of the meeting on Thursday.
(ESDs) may have questions about whether the notice must be posted by a certain time (e.g., by 5:00 p.m. on Friday for a 5:00 p.m. meeting on the following Thursday), but the bill does not address business hours. The bill strictly changes the current 72-hour requirement to “at least three business days before the scheduled date of the meeting.”
The next section is from TML's discussion of "city holidays" and regular closure of city offices. While we're not aware of any ESDs with "ESD holidays", we're including the section for completeness:
In addition, the new provisions do not define how city holidays may impact the three-business-day calculation. However, looking to other definitions of “business day” in state law may offer guidance. The Public Information Act (PIA) defines “business day” as a day other than: (1) a Saturday or Sunday; (2) a national holiday; (3) a state holiday; (4) the Friday before or Monday after a state or national holiday if the holiday occurs on a Saturday or Sunday and the governmental body observes the holiday on that Friday or Monday; and (5) a day in which the governmental body’s administrative offices are closed or operating with minimum staffing as a nonbusiness day. Though the PIA definition of “business day” does not have a direct bearing on the interpretation of the term used in the bill, which amends the Open Meetings Act, some cities might use it to conservatively consider council-designated holidays as non-business days.
As for compressed workweeks in which the city’s administrative offices are closed on Fridays, the Code Construction Act states that “in computing a period of days … [i]f the last day of any period is a … legal holiday, the period is extended to include the next day that is not a … legal holiday.” This could mean that when a city’s offices are regularly closed on Fridays and those Fridays are not legal holidays, they may still count as “business days.” However, it’s important to note that the intent of the new law is to give the public more notice, so cities in this situation should ensure that although their administrative offices are closed for business, the notice is accessible to the public.
Again, because the term ("business day") is not defined, (ESDs) should ultimately rely on the advice of their attorney until further direction is provided through attorney general opinions or court interpretations.
The TML legal department has created the following charts to help cities calculate the new three-business-day rule. The same should apply to Emergency Services Districts.
Chart 1 – Example without holiday
| Notice Date | Business Day 1 | Business Day 2 | Business Day 3 | Meeting Date |
| Tuesday | Wednesday | Thursday | Friday | Monday |
| Wednesday | Thursday | Friday | Monday | Tuesday |
| Thursday | Friday | Monday | Tuesday | Wednesday |
| Friday | Monday | Tuesday | Wednesday | Thursday |
| Monday | Tuesday | Wednesday | Thursday | Friday |
Chart 2 – Example including holiday: Veterans Day, Tuesday, November 11, 2025
| Notice Date | Business Day 1 | Business Day 2 | Business Day 3 | Meeting Date |
| Wed., 11/5 | Thurs., 11/6 | Fri., 11/7 | Mon., 11/10 | Wed., 11/12 |
| Thur., 11/6 | Fri., 11/7 | Mon., 11/10 | Wed., 11/12 | Thurs., 11/13 |
| Fri., 11/7 | Mon., 11/10 | Wed., 11/12 | Thurs., 11/13 | Fri., 11/14 |
| Mon., 11/10 | Wed., 11/12 | Thur., 11/13 | Fri., 11/14 | Mon., 11/17 |
Budget Posting
H.B. 1522 also requires that the notice for a meeting at which a governmental body will discuss or adopt its budget is required to include: (1) a physical copy of the proposed budget unless the proposed budget has been made clearly accessible on its website’s homepage; and (2) a taxpayer impact statement showing, for the median-valued homestead property, a comparison of the property tax bill in dollars from the current fiscal year to an estimate of the property tax bill in dollars for the same property for the upcoming fiscal year if the (ESD)’s proposed budget is adopted and if the budget funded by the no-new-revenue rate is adopted instead.
Note that while H.B. 1522 requires these additional documents to be included with the meeting notice for certain meetings on the budget, the bill does not affect or change the regular requirements of the meeting notice (i.e., the date, hour, place, and subject of each meeting held by the governmental body), as required by the Open Meetings Act.
Due to H.B. 1522’s September 1 effective date, some (ESDs) will need to comply with the budget posting requirements as soon as the upcoming budget and tax rate adoption cycle. (ESDs) that adopt their budgets before September 1 will not need to comply with the new law this year. However, some (ESDs) will adopt their budgets after the effective date of the bill. Those (ESDs) that provide notice of budget hearing, workshop, or meeting to approve the budget after September 1st should comply with the budget posting requirements in H.B. 1522 beginning this year.
What TML didn't cover: what level of posting is necessary if your governmental body is simply "discussing" the budget outside of the budget/tax rate adoption process? The issue remains open to interpretation.