TDLR Inspections and Complaints: How HVAC Enforcement Works

By Priya Raman · Updated September 30, 2026 · 7 min read

Short answer

TDLR enforces the Texas air conditioning and refrigeration (ACR) rules mostly by responding to complaints, plus inspections and investigations it opens itself. Penalties are set by a published sanctions matrix: lower-level violations such as missing license numbers in advertising fall in the hundreds to low thousands of dollars, while working or offering work without a license carries higher ranges and can include suspension or revocation. Check the current TDLR matrix, since it is reviewed periodically.

The Texas Department of Licensing and Regulation (TDLR) enforces the state’s air conditioning and refrigeration (ACR) law, Texas Occupations Code Chapter 1302, and the TDLR rules in 16 Texas Administrative Code Chapter 75. Enforcement mostly starts with a complaint, and it can also start from an inspection, an advertisement or a referral from another agency. If TDLR finds a violation, it applies a published sanctions matrix with penalty ranges by violation class. This article is general information, not legal advice. TDLR reviews its rules and matrix periodically, so check the current pages before relying on any figure.

Who does TDLR regulate in the ACR field?

TDLR licenses ACR contractors (Class A and Class B), and it registers or certifies technicians through its own system. It also regulates the companies that use those license holders: the rules place responsibilities on the contracting company as well as the individual. For the license structure, see Texas ACR license types: Class A vs Class B and Texas ACR endorsements explained.

How does a TDLR enforcement case start?

There are several common entry points:

A complaint from a customer. Property owners, tenants and building managers can file a complaint with TDLR about work, whether or not the contractor holds a license.
A complaint from a competitor or industry member. Contractors that hold a license have an interest in a level playing field, and they do report operators without a license.
A referral from a city inspector. If a building inspector notices work without a license or without a permit during an inspection, the matter may reach TDLR.
TDLR’s own review. TDLR investigators can look at advertising, websites, vehicles, job signs and public records, and they can conduct inspections.

TDLR publishes complaint statistics by program and fiscal year. Its ACR statistics show that a large share of cases involves license-holder background and record issues rather than workmanship, and that activity without a license is a recurring category. See the TDLR enforcement pages listed in the sources for current reports.

What happens after a complaint is filed?

TDLR describes the process in general terms on its complaints and enforcement pages. The usual sequence is:

Intake. TDLR reviews the complaint to see whether it falls within its authority.
Investigation. An investigator may request records, contact the parties, review documents and inspect the work or the advertising.
Review by enforcement staff. If the evidence supports a violation, the case moves to a prosecuting attorney or an enforcement team that decides on a sanction under TDLR’s enforcement plan.
Resolution. Many cases end with an agreed order that includes a penalty and sometimes corrective steps. If the respondent contests the matter, it can go to the State Office of Administrative Hearings (SOAH), where an administrative law judge hears the case.
Final order. The Commission or its delegate issues an order, which can include a fine, a probated or active suspension, or revocation.

TDLR also says its consumer protection role is not to act as a collection agency or to award damages. It can penalize licensees but generally does not resolve every dispute over money.

What are the penalty ranges?

TDLR publishes a penalties and sanctions page for ACR contractors with violation classes. The structure, as shown on the TDLR page when we checked, is:

Violation class	Example of the type of violation	Typical administrative penalty range
Class A	Missing license number in advertising, on a proposal or on an invoice	$500 to $1,000
Class B	More serious rule violations	$1,000 to $3,500, and/or suspension of up to one year
Class C	The most serious violations, including activity without a license	$2,000 to $5,000, with probated suspension up to revocation

Treat these numbers as indicative only. A Texas Register notice in 2026 shows that the Commission considered the penalty matrix, so the current figures may differ. The matrix also lets staff adjust the amount for factors such as the seriousness of the violation, prior history, harm to the public and efforts to correct the problem. The statute that gives TDLR general authority to impose administrative penalties is in Texas Occupations Code Chapter 51; read it directly for the statutory limits.

The penalty is only part of the cost. A case can lead to legal fees, lost business, mandatory corrective work, and in the case of a license holder, damage to the record that a future buyer or partner will review.

What does TDLR look at in advertising?

Advertising is one of the easiest things for an investigator to review because it is public. The rules require the license number in all advertising by an ACR contracting company that solicits ACR business, with narrow exceptions. TDLR can look at websites, social media, directory listings, trucks and yard signs. The topic is covered in more depth in Can you advertise HVAC services in Texas without a license?.

What can a company do to reduce enforcement risk?

These steps apply to any ACR business in Texas:

Verify every license. Check the TDLR license search for each contractor and each company before hiring or subcontracting. Confirm the class, endorsement and expiration date.
Keep insurance certificates current. Lapsed insurance can lead to license problems. See Texas ACR contractor insurance requirements.
Put the license number where the rules require it. That means advertising, proposals and invoices, and the company name and number on vehicles and job-site signs, as 16 TAC 75.71 describes.
Keep records. Training, permits, inspection results and customer communications help resolve complaints quickly.
Respond to TDLR promptly. A deadline missed in an investigation can make a small matter bigger.
Pull local permits. TDLR and city inspectors are separate systems. Passing one does not satisfy the other. See Austin vs Dallas mechanical code for the local side.

What about out-of-state or foreign companies?

A company based outside Texas, or outside the United States, has no special exemption. If it wants to do ACR work in Texas, it needs a contractor that holds a Texas license and must follow the same advertising and insurance rules. Companies in that position typically spend their early time on people, partnerships and learning the rules rather than on promotion.

Frequently asked questions

Does TDLR inspect HVAC jobs routinely?

TDLR does investigate and can inspect, but most ACR enforcement begins with a complaint or a referral. Local building inspectors handle the permit inspections for code compliance. Check TDLR’s current inspection and investigation pages for how it operates today.

Can a competitor file a complaint?

Yes. TDLR accepts complaints from anyone with information about a possible violation, and competitors, customers and local officials are all common sources.

Are the penalty ranges fixed?

No. They come from TDLR’s sanctions matrix and enforcement plan, and they are reviewed from time to time. TDLR can also adjust amounts based on the facts of a case. Check the current matrix and, for any actual case, talk to a Texas attorney.

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