How do you keep Texas HVAC work on the right code after 1 Sep 2026?

A Houston grocery has a walk-in condenser down. The ticket is a replacement, not a recharge. If the permit is pulled today, 1 Sep 2026, the TDLR ACR certified technician works to the 2024 mechanical codes and ASHRAE 15/34-2024. The same make of unit across the parking lot, permitted in August, can still finish under 2021. The TDLR electrician who lands the outdoor disconnect is on the 2026 NEC. Do not assume a GFCI device is required on that listed HVAC outlet as of today. TDLR kept the exception, with no expiration.

What actually changed on 1 Sep 2026?

This is a TDLR practice-code change for people who already hold Texas licenses. It is not a statewide energy-code upgrade, and it is not a 2026 national HFC step-down. The Texas Commission of Licensing and Regulation adopted the rules on 28 Jul 2026. They were filed with the Secretary of State on 12 Aug 2026 and published as Adopted Rules in the 28 Aug 2026 Texas Register. They take effect 1 Sep 2026.

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For ACR, Occupations Code §1302.101 is why TDLR sets the practice codes. The adopted text at §75.110, republished with changes, is:

• (a) Effective 1 Sep 2026, the commission adopts the 2024 IRC, IMC, IFGC and UMC.
• (b) The 2021 codes remain in effect through 31 Aug 2026. All air conditioning and refrigeration work permitted or started before 1 Sep 2026 may be completed under the 2021 editions.
• (c) For those 2024 codes, references to ASHRAE 15-2022 are modified to ASHRAE 15-2024, and references to ASHRAE 34-2022 are modified to ASHRAE 34-2024.

TDLR reads (b) as work permitted before 1 Sep may finish under 2021 even if it is physically performed later.

For electricians, Occupations Code §1305.101(a)(2) requires TDLR to adopt the most recent NEC after it is published. §73.100 was adopted without changes, so this Register issue does not reprint the rule. Subsection (a) adopts the 2026 NEC effective 1 Sep 2026. Subsection (b) is the amendment.

Which jobs stay on 2021, and which move to 2024?

The split is the permit or start date, not the day the technician arrives. Texas sites only.

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Write the permit date on the work order before anyone is dispatched. A replacement permitted this morning and a repair that started in August should not be worked as if they were the same job. If you are deciding whether that condenser is a repair or a replacement, use the same repair or replace check you already run. The code edition follows the permit, not the invoice.

What did TDLR do with outdoor HVAC GFCI?

Do not assume the outdoor HVAC GFCI exception died today. The 2026 NEC, as published, puts GFCI protection back on certain outdoor outlets at 210.8(F). Exception No. 2 says GFCI protection shall not be required for listed HVAC equipment. That exception, as published, expires 1 Sep 2026. TDLR did not adopt that sunset.

The prior Texas electrical code was the 2023 NEC. That edition did not include that outdoor-outlet GFCI requirement. Compatible high-frequency GFCI devices are not yet widely available. Nuisance trips on outdoor HVAC can take cooling offline in August. That is why TDLR kept the exception.

The adopted wording of §73.100(b), from the March 2026 proposal that was adopted as published, is: pertaining to NEC Section 210.8(F) Outdoor Outlets, the department adopts Exception No. 2, relating to the exemption of listed heating, ventilation, and air conditioning equipment, without expiration.

That exception is listed HVAC equipment. TDLR declined to extend it to refrigerators or other 240-volt outlets. Do not write a storewide GFCI waiver from this rule.

What did this not change?

• Who may hold a TDLR ACR certificate or a TDLR electrical license. Only the practice codes those license holders work to.
• EPA 608. Still required before refrigerant work is dispatched.
• Texas energy code. This adoption is ACR and electrical practice, not a commercial energy-code upgrade.
• A 2026 national HFC step-down. Do not recode the ticket as a refrigerant-phase job because the date is 1 Sep.
• Local amendments. A city can still add requirements on top of TDLR practice codes. Confirm the AHJ for that address.

What should you check before you dispatch?

Run this on Texas sites today. Non-Texas sites are not on this rule.

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The people on the ticket are a TDLR ACR certified technician and, where the disconnect or outdoor outlet is in scope, a TDLR electrician. Their HVAC vendor of record does not change because the code edition changed. Confirm they know which edition that permit is on before they leave the shop.

What happens if you ignore the date?

New Texas ACR work permitted or started today, worked as 2021 practice, is a TDLR and AHJ miss. So is an outdoor HVAC electrical ticket that treats listed-equipment GFCI as required as of 1 Sep 2026. The first mistake shows up as a failed inspection or a rejected permit. The second shows up as a GFCI device on a condenser that nuisance-trips and takes cooling offline. TDLR kept the exception because those outages were the risk.

What is still unclear?

Local amendments sit on top of TDLR practice codes. The AHJ at that address still has the last word on what it will inspect. TDLR may publish non-rule guidance on the ACR transition. As of the Register issue this guide is written from, it has not. This is not legal advice. Read the adopted rules, then confirm the permit and the AHJ before the first 1 Sep dispatch.

Pebble keeps the permit date and the code edition on the work order, so a Texas HVAC ticket opened today is not worked as last month's 2021 job. The TDLR ACR certified technician and the TDLR electrician still have to be on the ticket before anyone is dispatched.

ReferenceTexas Register, 28 August 2026, Adopted Rules, Title 16, Economic Regulation