Texas Does Not License Roofing Contractors at the State Level
Texas has no state roofing contractor license. The Roofing Contractors Association of Texas states on its own licensing page that the Texas Department of Licensing and Regulation does not administer licensure for roofing contractors, and that anyone can call themselves a roofer in Texas without being licensed, insured, or registered with the state. The City of Austin says the same about the general contractor role: in Texas, anyone can be a general contractor, including homeowners, and a state license is not required. That is why this page sets licensed to false. What Texas does regulate is conduct around the work. The Texas Department of Insurance polices the line between roofing and insurance adjusting, the Legislature bars roofers from absorbing a customer's deductible, the Business and Commerce Code gives buyers a three business day cancellation right on door-to-door sales, and the Comptroller sets how roofing jobs are taxed. Cities then add their own permit and registration rules, and those rules differ from one metro to the next. For a contractor, the practical result is simple. You cannot advertise a state roofing license because none exists. You can advertise real things: city registration where a city issues one, a voluntary industry credential if you hold it, insurance you actually carry, and years in business you can document. A roofer who builds marketing around the word licensed should be able to say exactly who issued the license, because a homeowner can ask, and the Texas Attorney General takes reports of deductible violations at 800-621-0508. The sections below cover each layer in the order a working roofer meets them: insurance law, storm sales rules, city permits, the voluntary credential, and the business basics.
Sourcesrcat.net 1austintexas.gov 2rcat.net 3
The Insurance Code Rule: A Roofer Cannot Act as a Public Adjuster
The rule that matters most to Texas roofers sits in Insurance Code section 4102.163. The current text reads: a contractor may not act as a public adjuster or advertise to adjust claims for any property for which the contractor is providing or may provide contracting services, regardless of whether the contractor holds a license under the chapter or is authorized to act on behalf of the insured under a power of attorney or other agreement. Two details deserve attention. First, the ban applies even if the contractor holds a public adjuster license. Second, a homeowner's signed authorization does not cure it. House Bill 2103, effective September 1, 2019, removed the word roofing from the section, so the ban now covers any contractor, not only roofers, and it applies to property the contractor may provide services to, not only property it is already working on. The Texas Department of Insurance summarizes the rule in plain terms: Texas does not allow a roofer or contractor to act as a public insurance adjuster on insurance claims if they are also doing the work, and you cannot advertise that you would do so either. The statute also directs the insurance commissioner to adopt rules to implement and enforce it. In practice, this means a roofer can sell a roof and can write an estimate, but the roofer cannot take charge of the claim itself. Anyone who wants to represent policyholders on claims must do that work for customers whose roofs they will not touch, and must hold the adjuster license the Insurance Code requires. Most storm restoration companies keep the two functions fully separate for that reason.
Sourcescapitol.texas.gov 1tdi.texas.gov 2tdi.texas.gov 3
What a Roofer May Say in Advertising and on a Website
The Texas Department of Insurance names specific problem language in its guidance for roofers. Your websites, ads, and other materials must not say or imply that you will act as both contractor and adjuster on a project. The department lists these examples of improper language or conduct: offering to negotiate claim settlements or file a claim for the policyholder; promising to recover every dime you are owed from an insurer; advertising to help homeowners avoid incorrect settlement pricing; and telling others, including insurance companies, that you represent the policyholder or can speak for them on coverage issues. The department also points to Texas Administrative Code, Title 28, section 21.102(1), which defines advertisement to include a website, so the rule reaches your service pages, your Google Business Profile text, and your landing pages, not only printed flyers. For a roofing company that wants to win storm work, the compliant message is about the roof: free inspection, documented damage photos, a written estimate the homeowner can hand to the insurance company, and clear pricing. The homeowner files and manages the claim, or hires a licensed public adjuster who has no roofing role on the job. Contractors may provide estimates and discuss those estimates and other technical information with an insurer or its adjuster, according to the department's 2024 disaster bulletin, so explaining a scope of work to an adjuster is allowed. What is not allowed is promising to fight the claim for the customer. Texas also has no state roofing license number that must appear on trucks or estimates, since no such license exists, and no state display rule for roofers was found in the sources checked.
Sourcestdi.texas.gov 1tdi.texas.gov 2
Public Adjusters, Licensing, and Conflicts of Interest
Texas requires public insurance adjusters to be licensed by the Texas Department of Insurance. The department's July 2024 storm bulletin states that all public insurance adjusters must be licensed, that the Insurance Code carries both civil and criminal penalties for violating that requirement, and that consumers have the right to contract with a licensed public adjuster under Insurance Code section 4102.007. The same bulletin lists conflict of interest rules that touch roofing directly. Licensed adjusters may not adjust roofing losses for an insurer if the adjuster is a roofing contractor, provides or sells roofing services or products, or is a controlling person in a roofing-related business. A roofing contractor may not act as an adjuster or advertise to adjust claims for any property that the contractor is providing or may provide roofing services to. For public adjusters who advertise, the bulletin adds that ads and signs must include the adjuster's address and license number, that the name on the ad must match the license record, and that solicitation of clients is prohibited during a disaster. Those advertising rules apply to adjusters, not to roofers, but roofers should know them because homeowners often hear from both groups after the same storm. A roofer who refers a customer to a public adjuster should confirm that the adjuster's license is active. The department runs a public search where anyone can look up an agent or adjuster by name or license number and see contact details. Check the license before you make any referral.
Sourcestdi.texas.gov 1tdi.texas.gov 2
The Deductible Law: Chapter 707 and Business and Commerce Code 27.02
House Bill 2102, also effective September 1, 2019, created Insurance Code Chapter 707 and rewrote Business and Commerce Code section 27.02. Section 707.002 says a person insured under a property insurance policy shall pay any deductible that applies to a first-party claim. Section 27.02 then makes it an offense for a seller of goods or services to advertise or promise to provide a good or service that will be paid from a property insurance claim while, without the insurer's consent, paying, waiving, absorbing, or declining to charge or collect the insured's deductible. The same offense covers providing a rebate or credit that offsets all or part of the deductible, and assisting the insured in avoiding payment in any other manner. It also applies to a contractor who performs the work knowing the insured will pay from claim proceeds and then waives or absorbs the deductible. The offense is a Class B misdemeanor. The Texas Department of Insurance describes the penalty as up to a $2,000 fine and up to six months in jail. Section 707.004 lets an insurer that issued a policy with replacement cost coverage refuse to pay withheld recoverable depreciation, also called a replacement cost holdback, until it receives reasonable proof that the policyholder paid the deductible. The statute lists a canceled check, money order receipt, credit card statement, or a copy of an executed installment plan or financing arrangement as reasonable proof. For roofers, the takeaway is that the phrase we will cover your deductible cannot appear in ads, texts, door hangers, or sales scripts. Financing the deductible through a written installment plan is different from waiving it, because the homeowner still owes the full amount.
Sourcescapitol.texas.gov 1tdi.texas.gov 2
The Required Notice in Contracts of $1,000 or More
Section 27.02(b) of the Business and Commerce Code adds a contract requirement. A contract to provide a good or service that is reasonably expected to be paid wholly or partly from the proceeds of a property insurance claim, and that has a contract price of $1,000 or more, must contain a specific notice in at least 12-point boldfaced type. The notice states that Texas law requires a person insured under a property insurance policy to pay any deductible applicable to a claim, and that it is a violation of Texas law for a seller who reasonably expects to be paid from claim proceeds to knowingly allow the insured to fail to pay, or assist the insured's failure to pay, the applicable deductible. The enrolled bill applies this requirement only to contracts entered into on or after September 1, 2019. The Texas Department of Insurance repeats the requirement in its roofing guidance and tells contractors that insurers may ask policyholders for proof that the deductible was paid. In practical terms, a roofing company that sells insurance-funded repairs should build the notice into its standard contract template rather than adding it job by job. The trigger is what the seller reasonably expects, not what the contract says about payment, so a roofer who knows the customer is filing a hail claim should assume the notice applies. Contracts under $1,000, such as a small repair, fall below the threshold. Because the section refers to the statutory wording, a contractor should copy the notice from the statute itself, not paraphrase it. A contract without the notice does not automatically void the sale under the text reviewed, but it puts the seller in violation of the section, and the Attorney General takes complaints on these matters.
Sourcescapitol.texas.gov 1tdi.texas.gov 2
Door-to-Door Storm Sales and the Three Business Day Cancellation Right
Many storm restoration jobs start with a knock on the door, and Texas Business and Commerce Code Chapter 601 governs those sales. The Texas Attorney General explains that the chapter applies when a merchant solicits a sale at a place other than the merchant's place of business, the buyer agrees to buy at a place other than the merchant's place of business, and the buyer is purchasing more than $25 of goods or services. When the chapter applies, the buyer may cancel within three business days under section 601.051. The merchant must give the buyer a contract or receipt showing the date of sale, the merchant's name and address, and a statement of the right to cancel that includes an address for sending the cancellation notice. Those documents must be in the language principally used in the sales presentation, so a sale pitched in Spanish needs a Spanish contract. The buyer cancels by signing and dating the notice of cancellation and mailing it back before midnight of the third business day after the sale. The Attorney General adds that a sale may be void even after the three days pass if the salesperson failed to make required disclosures, citing section 601.201. After a valid cancellation, the salesperson has ten business days to refund the buyer. For a roofer, the fix is procedural. Carry compliant cancellation forms, hand over a complete copy at signing, and never start tear-off inside the cancellation window unless you are prepared to have the customer cancel. Some exclusions exist in section 601.002(b), and the statute itself, not this summary, decides whether a specific sale is covered.
Sourcestexasattorneygeneral.gov
Windstorm Inspection Rules for Coastal Re-Roofs
Roofers who work the Gulf Coast face an extra layer that has nothing to do with city hall. The Texas Department of Insurance Windstorm Inspection Program applies to structures in the designated catastrophe areas, called the first tier counties: Aransas, Brazoria, Calhoun, Cameron, Chambers, Galveston, Jefferson, Kenedy, Kleberg, Matagorda, Nueces, Refugio, San Patricio, and Willacy, plus certain Harris County cities east of State Highway 146, namely La Porte, Morgan's Point, Pasadena, Seabrook, and Shoreacres. To qualify for wind and hail coverage through the Texas Windstorm Insurance Association, new structures, alterations, additions, and repairs to existing structures, including re-roofs and roof repairs, in those areas must meet the department's windstorm building code and pass inspection. Compliance is documented through a Certificate of Compliance, known as the WPI-8, which shows eligibility for TWIA windstorm and hail coverage. The department's contractor guidance says the contractor normally coordinates the inspection dates and times, that inspections must happen during the construction phase, and that the products used should be approved by the department. It also says a WPI-8 is posted on the department's website after the inspector submits documentation to the Austin windstorm office, with three working days suggested for processing. The department adds that a homeowner can discuss corrective measures with both the inspector and the roofer if a project is disapproved. A roofer who works these counties without planning for the inspection can leave a customer without eligibility for TWIA coverage on the new roof, which is a sales problem as much as a compliance one. Roofers outside the first tier counties are not covered by this program.
Sourcestdi.texas.gov 1tdi.texas.gov 2
Houston: Roofing Permits and What the City Publishes
Houston publishes separate permit pages for residential and commercial roofing through the Houston Permitting Center. A Residential Roofing Permit covers a re-roof or roofing overlay on a residence. Its listed authority is the City of Houston Residential Code and Chapter 10 of the Houston Code of Ordinances. The page lists an administrative fee of $33.56, refers to the city fee schedule for the permit fee, and shows that plan review and inspection are required, that renewal is not required, that the permit is valid for six months, and that processing takes 10 business days. Applicants need a building permit application, a Declaration in Support of Application, and either the Roofing Overlay Only form, numbered CE-1104, or the Residential Re-Roof Only Worksheet, numbered CE-1109. Applications go through the iPermits portal, and the permit and worksheet must be on site for inspection. The Commercial Roofing Permit works the same way for a new roof or overlay on a commercial structure, with a Commercial Re-Roof Only Worksheet, numbered CE-1076, or the overlay form, and two sets of plans where applicable. Depending on scope, a commercial job may need approval from groups such as structural, fire marshal, stormwater, or floodplain reviewers. Neither page states that a roofing company must hold a separate city roofing license to pull the permit. A search result listed a Registered Roofing Contractors List on a Houston Public Works document site, but that page could not be fetched, so this page makes no claim about it. Confirm current registration requirements with the Houston Permitting Center before bidding.
Sourceshoustonpermittingcenter.org 1houstonpermittingcenter.org 2
Dallas: Re-Roof Permits and Contractor Registration
The City of Dallas Building Inspection division handles roofing permits, and its published pages describe them as a permit matter rather than a roofing license matter. The single-family residential guidance says a roofing permit for damage to shingles and deck only may be obtained over the counter at the district offices, at the Oak Cliff Municipal offices, or online. Storm damage that reaches structural roof joists or rafters is handled as a building permit instead. The same page says replacing large areas of a roof or an entire roof requires a re-roof permit, while minor repairs to roofing or roof vents do not require one. The Building Inspection FAQ says a re-roof permit can be obtained at a district office, and it states that re-roofing of a single-family or duplex dwelling does not need a permit if the value of the work does not exceed $500, except in historic, conservation, and planned development districts that carry additional requirements. That dollar threshold comes from the city's own FAQ, and a roofer should confirm it has not changed. The single-family page also notes that registered contractors may apply for trade permits online through the city's permit portal, and the city's FAQ explains that plumbing and mechanical contractors need state licenses under the Texas Plumbing License Law and Texas Mechanical License Law. Roofing is not named in that list. A roofing company that also sells HVAC or plumbing work as part of a storm job needs the state trade licenses for those parts, held by the person the state licenses, and city registration where Dallas requires it. Call Dallas Building Inspection at 214-948-4480 to confirm the current registration steps for a roofing-only company.
Sourcesdallascityhall.com 1dallascityhall.com 2
Austin and San Antonio: Registration Tied to the Permit
Austin and San Antonio both tie contractor registration to the permit, and neither page reviewed describes a separate roofing license. Austin Development Services states that before beginning any construction associated with a building permit and trade permits, trade contractors, general contractors, and homeowners acting as contractors must register with Building and Trade Contractor Services. Once registered, the contractor can be assigned to the applicable permit and can begin construction and inspections. The general contractor listed on the permit must have an Austin Build + Connect portal account, and the page says a general contractor must register before being assigned to a building permit. The page states plainly that in Texas anyone can be a general contractor and that a state license is not required. Trade contractors for mechanical, electrical, and plumbing work must appear in person with a state-issued identification card and their state trade license. San Antonio's Re-Roof Permit Application, a Development Services form, asks for the registration holder and a City Registration number, and it has a homeowner-only section requiring the owner to attest to owning and occupying or renting the residence for 12 months after the project under City Code 10-115(a)(1). The form also says a maximum of two layers of roofing material is allowed under the International Residential Code, that an engineer's assessment report is required if the roof slope changes or the material changes to tile, and that mechanical, electrical, and plumbing permits for extended roof penetrations must be secured by licensed trade contractors. The San Antonio contractor registration pages returned an access denied response, so registration fees and qualifications there are not stated here.
Sourcesaustintexas.gov 1docsonline.sanantonio.gov 2
The RCAT Licensed Roofing Contractor Program (Voluntary)
The Roofing Contractors Association of Texas runs a voluntary credential it calls the RCAT Licensed Roofing Contractor program. RCAT states that the license is provided through and fully managed by the association, not by any state agency, and that the program is voluntary self-regulation. It licenses individuals, not companies, though the license holder must own, operate, or manage a qualifying roofing company, and that company may then market itself as licensed. An applicant must be a principal in a Texas roofing company domiciled in the state for at least two continuous years before applying, and the company must have a fixed address with a physical location. Residential applicants must show $300,000 combined single limit general liability insurance or evidence the firm can obtain a $100,000 surety bond, property bond, or irrevocable letter of credit. Commercial applicants must show $500,000 in general liability or the same $100,000 bond alternative. Applicants also show workers compensation coverage or a filed DWC Form-005 notice of no coverage. Each person must pass a business and safety exam plus a residential or commercial roofing exam, with 70 percent or better on each, taken online within one year of approval. Exam fees are $550 for one exam and $750 for both for RCAT members, and $850 and $1,050 for non-members. The license runs one year and renews with the same qualifications, 8 hours of approved continuing education, and a $250 annual fee. Because the credential is private, advertise it as an RCAT license and never as a state license.
Sourcesrcat.net
Insurance, Workers Compensation, and Sales Tax for Texas Roofers
Texas sets no statewide general liability minimum for roofers in the sources reviewed, so the insurance figures a homeowner or builder asks for come from contracts, cities, and voluntary programs. The RCAT credential, for one, names $300,000 residential and $500,000 commercial general liability, and those numbers apply only to that program. Workers compensation works differently from many states. The Texas Department of Insurance explains that private employers can choose whether to provide workers compensation coverage, and employers that decline are called non-subscribers. Non-subscribers must post a notice of no coverage in English, Spanish, and any other language needed, give written notice to new employees, and file a notice of no coverage with the Division of Workers Compensation between February 1 and April 30 each year, after hiring the first employee, and after ending a policy. Employers with five or more employees must also report certain injuries and illnesses. Roofing is dangerous work, and general contractors and property owners often require proof of coverage before letting a crew on a site. Sales tax depends on the property. The Comptroller says labor to repair, remodel, or restore residential real property is not taxable, and that on a contract that separates materials from labor the contractor collects tax on materials while the construction labor charge is not taxable. For nonresidential property, repair or remodeling includes reroofing, and those jobs are taxable. Mixed-use properties need separate guidance from the Comptroller. Confirm the treatment of your specific contract type with the Comptroller before you invoice.
Sourcesrcat.net 1tdi.texas.gov 2comptroller.texas.gov 3
Verifying a Texas Roofer and Reporting Problems
Because Texas issues no roofing license, a customer cannot verify a roofer on a state license database. Verification runs through several separate checks. For the insurance side, the Texas Department of Insurance offers a public search to look up an agent or adjuster by name or license number, which a homeowner can use to confirm that a public adjuster is licensed. For voluntary credentials, RCAT publishes a searchable directory of roofing contractors who participate in RCAT membership, the licensed contractor program, or both. For city standing, the building department that issues permits is the place to ask, and Austin's registration page and Houston's permit pages show that permits are tied to the applicant. The Attorney General's home improvement guidance tells homeowners to choose a contractor with an established physical address, to get written bids from more than one contractor, to ask for references and visit finished jobs, and to be cautious when a salesperson appears uninvited. The Texas Department of Insurance adds practical tips: get written estimates on company letterhead with clear contact information, check references and phone numbers, do not pay in full up front, do not make final payment until the job is done, and never sign a contract with blanks. Violations of the deductible law can be reported to the Attorney General's Consumer Protection Hotline at 800-621-0508. Contractors can turn these checks into marketing strengths by putting their address, insurance details, city registration numbers, and RCAT status on their website, where a homeowner can confirm them before calling.
Sourcestdi.texas.gov 1rcat.net 2texasattorneygeneral.gov 3tdi.texas.gov 4austintexas.gov 5