Change contract companies in the middle of a renewal cycle and a reasonable question comes up: who has my training record now? The answer is not the one most officers assume.
The Record Does Not Travel With You
§35.161(a) tells an employer to maintain proof of continuing education in the employee’s personnel file. It also says a renewal application may not be submitted until the required minimum hours have been earned, and that the licensee indicates completion on the renewal application. Read together, that leaves the company holding the file and the officer holding the declaration. When the officer leaves, the file stays behind. The obligation to be able to prove the hours does not.
Which is why §35.161(m) matters more than it looks. Attendees keep their own certificates of completion for two years and furnish copies to the department on request. Your personal copy is the one that survives a job change, and in a market like east Dallas County, where retail centers, entertainment and event venues, industrial parks and the warehousing that has filled in along the I‑635 and US‑80 corridors turn over contract security regularly, officers move between employers often enough that this is a live problem rather than a theoretical one. Keep the certificate yourself. Do not rely on a former employer’s filing cabinet.
On the employer side the same rule cuts the other way. When you onboard an armed officer mid-cycle, the personnel file you are starting is empty. Ask for the certificate at hire, not at renewal.
What the Six Hours Are
§35.161(g) requires commissioned security officers and personal protection officers to complete six hours of continuing education, met by completing the renewal portions of the Level III or Level IV training course, as applicable, with all of it taught by department-approved training schools and instructors. A commissioned security officer must also submit a firearms proficiency certificate with the renewal application.
Our armed security renewal class delivers the classroom hours 100% online, and the price covers the online training only. The in-person firearms qualification is not included and is scheduled separately after you finish online. If a shotgun is authorized on your post, §35.146(b) sets a biennial familiarization of six rounds of “00” buckshot in connection with renewal of a commissioned security officer: range business, not classroom business.
Your New Employer’s Training Program Won’t Cover It
This surprises officers who join a larger company and are told the in-house program takes care of continuing education. For unarmed staff at a company with ten or more licensed employees, there is such an exemption. For you, there is not. §35.162(d) states the in-house exemption does not apply to commissioned security officers or personal protection officers. And if someone suggests a credit from an outside provider instead, §35.162(f) says outside-entity credits may not be used to satisfy the requirement for those officers either. Approved school, or it does not count. Regardless of who signs your paycheque.
Timing: Measure From Your Expiration Date
§35.161(n) makes continuing education valid only if completed within the two-year period preceding the license’s current expiration date. That is worth saying precisely, because “renew every two years” is the shorthand everyone uses and it hides the trap: the window is anchored to your expiration date, so hours completed too far ahead of it are wasted. Supervisors running a roster hit the same issue from the other side. Officers hired at different times have different windows, so a single group training date will not serve everyone on the crew.
Four Clarifications Worth Having in Writing
- Unarmed officers owe nothing here. §35.161(b) specifically exempts noncommissioned security officers from continuing education, so a Level 2 non-commissioned officer has no CE obligation at all.
- Level 3 and Level 4 are separate licenses. Level 3 is the commissioned security officer; Level 4 is the personal protection officer, the bodyguard credential. They share a renewal pathway under §35.161(g) because each is directed to the renewal portion of its own course, not because one outranks the other.
- A long gap changes the answer. Under §35.141(d), a person inactive or expired and not employed in the industry for three years or more must submit current training certificates to the department, so the full Level 3 commissioned officer course may be what is needed rather than a renewal.
- Military service gets extra time. §35.182 gives service members two additional years for a continuing education or other renewal-related requirement, and §35.181 waives late-renewal penalty fees for them.
When the class is finished you receive the certificate referred to here as the PSP 31. Under §35.162(b)(3) it shows your name and license number, date of attendance, number of hours and courses attended, signed and dated by the school director, and the school retains its records for two years. Check it before you file it.
All of the above is set out in 37 TAC Chapter 35, with licensing handled by the Texas DPS Private Security Bureau. If your circumstances do not fit neatly, our FAQ covers the usual complications.
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