Overview
Navigating Texas SB 1036: Palmetto & LightReach Lead the Way in Solar Consumer Protection
The Texas residential solar market is entering a new era of accountability. In response to heightened scrutiny and legislative action surrounding industry sales practices, Texas passed Senate Bill 1036-the Residential Solar Retailer Regulatory Act (RSRRA).
The law directs the Texas Department of Licensing & Regulation (TDLR) to oversee solar retail operations. Following thorough stakeholder input, the TDLR finalized strict standards covering mandatory retailer registration, standardized disclosures, and clear contract terms.
With these state regulations taking effect on September 1, 2026, Palmetto LightReach have launched the Texas Solar Consumer Protection Plan. This proactive initiative ensures full compliance across sales partners, EPCs, and internal teams-setting a higher standard of transparency and trust for Texas homeowners.
Key Partner Requirements & Milestone Updates
To support ongoing operations under state law, Palmetto is integrating new Partner and Milestone (M1) requirements into the project workflow for all Texas solar leases and PPAs.
Partner Requirements:
TDLR Registration
For Sales Organizations
Register: Complete your organizational registration directly on the TDLR portal.
Submit: Upload your TDLR registration number and proof of registration into Palmetto’s Safeturf system.
Internal Validation: Palmetto validates your credentials and assigns your organization number within the Finco portal.
For Individual Sales Representatives
Register: Complete your salesperson registration on the TDLR portal.
Submit: Submit your individual registration number via Safeturf.
Internal Validation: Palmetto verifies your registration status and assigns your number in the Finco portal and/or via the Recheck validation process.
Critical Requirements & Next Steps
Mandatory for Agreement Generation: A valid TDLR registration number is strictly required to generate any Texas Solar Agreement and must be clearly printed on the agreement document itself.
Annual Renewal: Registration numbers expire annually; sales orgs and reps must submit renewed documentation prior to expiration to prevent disruption.
Compliance Checklist: Both EPCs and sales reps must execute the mandatory Compliance Checklist within the Safeturf workflow, where links to essential regulatory resources and state guidance are provided.
M1 Requirements:
To comply with Texas SB 1036, all Texas solar projects now require two mandatory M1 milestone approvals before proceeding.
1. Consumer Disclosure Form
Requirement: EPC uploads the signed Consumer Disclosure Form.
Customers 65+ (State Law Requirement): Must submit TWO copies:
E-Signed Version: Validates signature authenticity and timestamp.
Paper Signed Copy: Satisfies physical compliance under state law.
QA/QC Verification: Checks for completion, valid signatures, proof it was signed on or before the Solar Agreement date, and the paper copy for seniors (if applicable).
2. Sales Rep Attestation
Requirement: Sales rep submits confirmation that the Marketing Brochure was delivered to the homeowner at least 24 hours before the Solar Agreement was signed.
QA/QC Verification: Checks for document completion.
Note: Projects missing either requirement will be held at M1.
Registration Guidelines by Partner Type
State law distinguishes requirements based on licensing status, though all customer-facing sales reps face individual obligations:
Sales Sub-Organizations & Retailers: Entities offering solar leases or sales that do not hold an active Texas Electrical Contractor license must register annually as a Solar Retailer ($350 annual fee) via the TDLR Residential Solar Retailers Portal.
Electrical Contractors (EPCs): Licensed electrical contractors are exempt from company-level solar retailer registration. However, they must still enforce all disclosure, brochure, and milestone requirements for their agreements.
Individual Sales Representatives: No exemptions apply. Every individual salesperson selling residential solar in Texas must register annually as a Solar Salesperson ($56 annual fee) through tdlr.texas.gov, even if direct-employed by a licensed Electrical Contractor.
Requirement | Solar Salesperson | Solar Retailer Organization |
TDLR Registration Form
| Required | Required |
Criminal History Questionnaire
| Required | Required |
Associated Retailer / Rep Info
| Link to Retailer | Submit Sales Rep Roster |
Proof of General Liability Insurance
| — | Required |
Annual Fee
| $56 | $350 |
Safeturf Verification & Implementation Roadmap
Registration numbers for both organizations and individual sales personnel will be collected and managed through Palmetto’s Safeturf workflow. Once submitted, Palmetto validates these credentials and populates the rep’s registration number directly onto all generated customer agreements.
Launch Strategy:
(September 1, 2026): Milestone updates and disclosure forms become mandatory for all new Texas accounts. During the initial soft-launch phase, missing TDLR registration numbers will not block contract generation while teams onboard, but compliance teams will prioritize onboarding large partners immediately.
Full Enforcement (Date TBD): Palmetto will announce a future deadline when active TDLR registration numbers become mandatory to generate any new Texas customer agreements.
For questions or assistance with compliance onboarding, partners can reach out directly to their Relationship Manager or email Palmetto Support.
Customer-Facing Disclosures (Clear Facts)
The following confirmations will be added to the Clear Facts process for Texas customers:
"I received the Residential Solar Educational Brochure 24 hours before executing an Agreement and reviewed and executed the Residential Solar Consumer Disclosure Form before executing an Agreement."
For customers 65+ only: "I received the Residential Solar Educational Brochure 24 hours before executing an Agreement and reviewed and executed a paper copy of the Residential Solar Consumer Disclosure Form before executing an Agreement."
"I provided an active email address that I have access to and consented to executing an Agreement electronically. I understand that a copy of my Agreement (electronic or paper) can be requested from Palmetto at any time by emailing [email protected]."
FAQ
Do I need to be a registered Solar Retailer to create new LightReach accounts? | Any entity engaged in solar retail without an electrical contractor's license must register as a Solar Retailer. |
When do these requirements begin? | September 1, 2026. |
How do Solar Retailers and Solar Salespersons get registered? | |
Do registrations have to be renewed? | Yes, annually. |
Since TDLR Licensed Electrical Contractors are exempt from Solar Retailer registration, are their salespeople also exempt? | No. Even if an individual's employer is a licensed Electrical Contractor, the individual still needs to register with TDLR as a Solar Salesperson. |
Resources
Questions? Reach out to your Relationship Manager or LightReach Compliance.