If you run armed posts anywhere in the Houston market, the continuing education rule is not really an officer problem. It is a file problem: and the file is yours.

Houston carries more armed security posts than almost anywhere else in the state, and the reason is structural: ship channel terminals, petrochemical and refining operations along the east side, the medical complex, corporate campuses along the Energy Corridor, and an enormous distribution and logistics footprint feeding the port. A contract company here can easily be carrying dozens of commissioned officers across sites that never see the same supervisor twice in a week. That is exactly the situation the renewal rules were not designed to be friendly to.

The Obligation the Employer Actually Owns

Read §35.161(a) carefully and you will find it splits the job three ways. A renewal application may not be submitted until the required minimum continuing education hours have been earned. Proof of completion must be maintained by the employer in the employee’s personnel file. And the licensee indicates completion on the renewal application. The officer does the class, the officer makes the declaration, but the document that has to sit in a folder and survive a records request is on the company.

Officers have a parallel duty under §35.161(m): attendees keep their own certificates of completion for two years and furnish copies to the department on request. So there should be two copies of every certificate in circulation. One in the personnel file, one with the officer. In practice, in a market with Houston’s turnover, the officer’s copy is often the only one that survives a move between contract companies.

The In-House Training Exemption Does Not Reach Your Armed Officers

This is the single most expensive misunderstanding a Houston security manager can carry. Companies with ten or more licensed employees have an in-house continuing education exemption available to them, and plenty of larger operations here qualify comfortably. But §35.162(d) states the exemption does not apply to commissioned security officers or personal protection officers. Whatever your internal training program covers, it does not cover them.

The companion provision closes the other door. Under §35.162(f), continuing education credits earned through outside entities may not be used to satisfy the requirement for commissioned security officers or personal protection officers either. Between those two rules and the requirement in §35.161(g) that the education be taught by department-approved training schools and instructors, an armed officer’s six hours have exactly one legitimate source: an approved school. Not your own classroom, not a generic online CE vendor, not a training credit picked up at a conference.

What the Six Hours Consist Of

§35.161(g) requires six hours of continuing education for commissioned security officers and personal protection officers, satisfied by completing the renewal portions of the Level III or Level IV training course, as applicable. A commissioned security officer must also submit a firearms proficiency certificate with the renewal application. Our armed security renewal course delivers that classroom requirement 100% online, which is the practical part for a roster spread across three shifts and half the county. The price covers the online training only: the in-person firearms qualification is not included and is scheduled separately after the online portion is finished.

If a shotgun is part of a post’s authorized armament, note that §35.146(b) sets a biennial familiarization of six rounds of “00” buckshot in connection with renewal of a commissioned security officer. That belongs to the range side of the process, not the classroom.

Timing a Roster, Not a Person

The mistake supervisors make when they batch training is scheduling too early. §35.161(n) provides that continuing education is only valid if completed within the two-year period preceding the license’s current expiration date. That is a validity window attached to each individual license, not a company-wide cycle you can align. Put four officers through a class together and you may find one of them sat in a course that will not count, because the window had not opened against his expiration date yet. Track expiration dates per officer and schedule against those.

Three Things Worth Flagging on Your Roster

1. Your unarmed officers are not in scope. §35.161(b) specifically exempts noncommissioned security officers from continuing education. If someone on the roster holds only a Level 2 non-commissioned license, there is nothing to schedule.
2. Level 3 and Level 4 are separate credentials. Level 3 is the commissioned security officer. Level 4 is the personal protection officer. The bodyguard credential, not a senior grade of commissioned officer. They share one renewal pathway because §35.161(g) points each to the renewal portion of its own course, but they are not the same license and should not be tracked as one column.
3. Long gaps change the answer. Under §35.141(d), someone inactive or expired who has not been employed in the industry for three years or more must submit current training certificates to the department. A rehire in that category may need the full Level 3 commissioned officer course rather than a renewal.

What a Compliant Certificate Looks Like

When you file the proof, know what you are filing. §35.162(b)(3) requires a continuing education school’s certificate of attendance to show the attendee’s name and license number, date of attendance, number of hours, and courses attended, signed and dated by the school director, with the school retaining its records for two years. On this site that certificate is referred to as PSP 31. If a document in a personnel file is missing the license number or the hours, it is not doing the job §35.161(a) asks of it.

One more provision that rarely comes up and quietly rescues people: §35.182 gives military service members two additional years to complete a continuing education requirement or any other renewal-related requirement, and §35.181 waives late-renewal penalty fees for service members. Given how many Houston officers come out of or remain in the reserves, it is worth knowing before you write someone off as lapsed.

You can verify all of it in 37 TAC Chapter 35, and licensing questions belong with the Texas DPS Private Security Bureau. Common roster scenarios are covered on our FAQ page.