Commissioned security officers and personal protection officers cannot do their continuing education in house because the Texas Administrative Code does not allow it. Their renewal hours have to come from the renewal portions of the approved Level 3 or Level 4 course, taught by a DPS-approved school and instructor. The in-house exemption that larger companies can get for other licensed employees specifically leaves armed officers and PPOs out, and credits from outside organizations do not count for them either.
If you run a company with a mix of unarmed and armed officers, that distinction matters every time a license comes up for renewal. Below is what the rules say, section by section, and how to handle armed renewals without turning each one into its own project.
What does the rule say about armed officer continuing education?
The governing section is 37 TAC §35.161(g). It requires commissioned security officers and personal protection officers to complete 6 hours of continuing education “by completing the renewal portions of the Level III or IV training course, as applicable.” That training may be taught only by department-approved schools and instructors.
The same subsection adds a second piece for commissioned officers: they submit a firearms proficiency certificate with the renewal application. So an armed renewal is not only a matter of logging hours. Plan for both parts when you schedule it.
Our company has an in-house CE exemption. Doesn’t that cover everyone?
No, and this is where companies get caught. Under 37 TAC §35.162(d), a company with ten or more licensed employees can obtain an exemption letter that lets it provide continuing education in house. That is useful for the rest of your licensed staff.
But the same subsection states that the exemption does not apply to commissioned security officers or personal protection officers. A training manager who runs an excellent in-house session still cannot use it to renew a commission. If your internal CE calendar lumps armed and unarmed staff together, split it now.
Can officers count training they took somewhere else?
Not toward an armed renewal. 37 TAC §35.162(f) says continuing education credits from outside entities, such as agencies, colleges, associations or other states, cannot be used for commissioned security officers or personal protection officers.
Officers often have good training on their records from a prior job, a college course or an industry conference. It may make them better at the post. It just does not satisfy §35.161(g). The only path the rule recognizes is the renewal portion of the approved course from an approved school.
Which officers on your roster does this apply to?
Sort your licensed staff into three groups before you plan anything:
- Noncommissioned security officers. Exempt from continuing education under 37 TAC §35.161(b). They do not need renewal hours.
- Commissioned security officers. Need the 6 hours through the applicable renewal portion of the approved course from an approved school, plus a firearms proficiency certificate with the renewal application (§35.161(g)).
- Personal protection officers. Need the 6 hours through the renewal portion of the applicable course from an approved school (§35.161(g)). The in-house exemption and outside credits are both off the table for this group too (§35.162(d) and (f)).
For many companies, the commissioned group is the big one, and it is the group whose lapses hurt most because those officers are usually staffing your highest-value armed posts.
When do the hours have to be finished?
Two rules set the window. First, 37 TAC §35.161(n) says continuing education is valid only if it was completed within the two-year period preceding the license’s current expiration date. Hours finished outside that window do not count toward this renewal.
Second, §35.161(a) says a renewal application may not be submitted until the required hours have been earned. An officer cannot file first and catch up on training later. The same subsection puts the recordkeeping on you: proof of the continuing education must be maintained by the employer in the employee’s personnel file.
In practice, that means the latest safe moment to book training is well before the expiration date, not the week of it. Pull every armed officer’s expiration date into one list and look for clusters. Officers whose dates fall near each other can renew together.
How do you run armed renewals as a group?
Armed Security Recertification is one of the single courses a company can book for a group through our group training program. The process is the same as any other group booking:
- Request pricing with the number of officers who are due. The minimum for a group is five.
- Pay one invoice, in advance, covering every officer. Officers pay nothing themselves.
- Submit one roster. Each officer receives an account and login by email automatically, already enrolled.
- Officers work through the online portion at their own pace, and any in-person session is booked afterward on a date that suits the group.
Your manager login shows who has started, who has finished and who has not signed in, scoped to your company only. That is the list you check before anyone files a renewal application, since §35.161(a) does not allow filing until the hours are done.
Any in-person portion can happen at your facility, with one flat travel charge starting at $1,500 and no per-mile billing, or at East Texas Rifle and Pistol Club in Longview, Texas, with no travel charge. If only two or three officers are due this quarter, they can enroll individually instead.
One renewal habit worth building
Review armed expiration dates on a fixed schedule, such as the first week of each quarter, and book renewals in batches. Doing it on a calendar keeps renewals from turning into emergencies and lets you bring the whole batch through on one invoice.
Renewal questions we hear from managers
Can an officer submit the renewal now and finish the hours afterward?
No. 37 TAC §35.161(a) says a renewal application may not be submitted until the required continuing education hours have been earned. Finish the training first, then file.
Who keeps the proof that an officer completed the hours?
The employer. Under 37 TAC §35.161(a), proof of continuing education must be maintained by the employer in the employee’s personnel file. File the certificate as soon as it arrives.
Do our unarmed officers need to be on the recertification roster?
Noncommissioned security officers are exempt from continuing education under 37 TAC §35.161(b), so they do not need renewal hours. For other questions about our courses, see the FAQs.
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