The City Desk · Interactive resource

Municipal AI
Governance Review

Texas cities have new AI responsibilities. Work through the questions, spot the issues that deserve attention, and leave with a city-ready action plan.

Answers stay in this browser tab. Nothing is submitted to Santos Law.
About 8–12 minutes · No login
Part 1 of 425%

Core governance

Start with the statewide baseline requirements applicable to Texas cities.

QUESTION 01Rule-based
Has the city adopted DIR's AI Code of Ethics?

Adopting the state code under 1 TAC § 219.11 is separate from adopting a general AI acceptable-use policy. Gov't Code § 2054.702(c); 1 TAC § 219.11 ↗

QUESTION 02Rule-based
Has an employee been designated as the city's AI Risk Officer?

The role can be assigned to an existing employee. The rule does not require a new full-time position. 1 TAC § 219.21(a) ↗

QUESTION 03Rule-based
Does the city have a process to identify and inventory heightened-scrutiny AI?

The rule requires a process to identify and inventory qualifying systems; a broader inventory of ordinary AI tools is also useful. 1 TAC § 219.21(b) ↗

QUESTION 04Rule-based
Did covered employees and officials complete annual certified AI awareness training?

For local government, covered employees and elected or appointed officials generally must have access to a government system or database and use a computer for at least 25% of their required duties. Check DIR's guidance for exceptions. Gov't Code § 2054.5191; DIR guidance ↗

QUESTION 05Rule-based
Did the city submit its annual training certification to DIR by August 31?

DIR uses a combined cybersecurity and AI compliance certification. Cities maintain individual completion records and do not upload each employee's certificate. Gov't Code § 2054.5191; DIR reporting guidance ↗

5 unanswered
Legal sources

Checked October 26, 2026. Requirements and DIR materials may change; always confirm the current rules and the city's particular circumstances.

From a checklist to an adopted city process.

Santos Law advises Texas cities on AI governance, public-sector policies, vendor agreements, and implementation. Please do not include privileged information in an initial inquiry.

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