Before you schedule a single McAllen officer for continuing education, run this down your roster. Four questions decide whether the hours will actually count.

- Is this officer armed? If the answer is no, stop. §35.161(b) specifically exempts noncommissioned security officers from continuing education.
- Which credential? Level 3 commissioned security officer and Level 4 personal protection officer are different licenses, and each renews through the renewal portion of its own course.
- When does the license expire? The validity window in §35.161(n) runs backward from that date, per officer.
- Who is teaching the class? For armed officers this is not a free choice, and the next section explains why.
Question Four Is the One That Trips Companies Up
Texas gives companies with ten or more licensed employees an in-house continuing education exemption. In the Rio Grande Valley, where a single contract covering warehouse and cross-dock operations along the border trade corridor can staff well past that threshold, plenty of employers qualify, and then assume their internal training program handles renewals. It does not. §35.162(d) provides that the in-house exemption does not apply to commissioned security officers or personal protection officers.
The second half of the trap is §35.162(f): continuing education credits earned through outside entities may not be used to satisfy the requirement for those same officers. So the workaround people reach for next, a general-purpose online CE vendor, a credit from an industry association, is closed too. §35.161(g) completes the picture by requiring that the continuing education be taught by department-approved training schools and instructors. One source, and it has to be an approved school.
Six Hours and a Proficiency Certificate
The requirement itself is compact. §35.161(g) calls for six hours of continuing education for commissioned security officers and personal protection officers, met by completing the renewal portions of the Level III or Level IV training course, as applicable. A commissioned security officer must additionally submit a firearms proficiency certificate with the renewal application.
That splits the renewal into two separate errands. Our armed security renewal course handles the classroom side 100% online, which makes it schedulable around the rotating shifts common on Valley retail, medical and logistics posts. The price covers the online training only. The in-person firearms qualification is not included and is arranged separately after the online portion. Where a post authorizes a shotgun, §35.146(b) sets a biennial familiarization of six rounds of “00” buckshot in connection with renewal of a commissioned security officer, and that also belongs to the range visit.
The Personnel File Is Not Optional Housekeeping
§35.161(a) is short and puts a duty on each party. A renewal application may not be submitted before the minimum hours are earned. Proof of completion must be maintained by the employer in the employee’s personnel file. The licensee indicates completion on the renewal application. Officers carry their own obligation under §35.161(m). Keep certificates of completion for two years and furnish copies to the department on request.
Know what a valid certificate contains before you file it. Under §35.162(b)(3), a continuing education school issues a certificate of attendance showing the attendee’s 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. On this site that document is called the PSP 31.
Why Batching a Roster Backfires
§35.161(n) says a continuing education course is only valid if completed within the two-year period preceding the license’s current expiration date. Note what that is: a validity window measured against one license, not a renewal interval you can synchronise across a team. Supervisors who put a whole shift through training on the same afternoon sometimes discover later that the newest officer’s hours fell outside his own window and do not count. Track expirations individually and schedule inside each one.
Two Roster Exceptions
A rehire who has been away from the industry is not a renewal candidate by default. §35.141(d) requires someone inactive or expired who has not been employed in the industry for three years or more to submit current training certificates to the department, which may mean the full Level 3 commissioned security officer course rather than the renewal. And a military service member gets latitude most supervisors do not know about: §35.182 allows two additional years to complete a continuing education or other renewal-related requirement, while §35.181 waives late-renewal penalty fees for service members.
Hiring managers building a pipeline should also remember where the ladder starts. An unarmed Level 2 security officer class is the entry point, and nothing on this page applies to those officers. The rules themselves are published as 37 TAC Chapter 35, licensing runs through the Texas DPS Private Security Bureau, and situations we get asked about repeatedly are collected on our FAQ page.

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