Irving has more corporate security posts per square mile than almost anywhere in Texas, and a steady number of officers on them assume the company handles renewal. The rule puts most of it squarely on the officer.

Three Conditions And One Document

Nothing about a renewal application can move forward until all four of the following are already settled:

1. The hours are finished. Six of them, earned, not enrolled in.
2. They came from an approved school. Not from your employer’s internal program and not from an outside CE provider.
3. They fall inside the right window. The two-year period preceding your current expiration date.
4. You hold a firearms proficiency certificate to submit with the application, if you are a commissioned security officer.

Unpacking The Three Conditions

Finished, before you file

§35.161(a) states that a renewal application may not be submitted until the required minimum continuing education hours have been earned. It then splits the recordkeeping in two: proof must be maintained by the employer in the employee’s personnel file, while the licensee indicates completion on the renewal application. That division is exactly where corporate-campus officers get tripped up. The employer-held file follows the employment relationship; the license follows you. Change contract companies mid-cycle, as officers in the Las Colinas office corridor frequently do, and it is worth confirming your proof made the move with you.

From an approved school, with no exceptions available

§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 IV training course, as applicable, and taught by department-approved training schools and instructors. Where Irving differs from smaller markets is the size of the employers: a great many armed posts here are staffed by contract firms large enough to run substantial in-house training. That changes nothing. §35.162(d) says the in-house continuing education exemption for companies with ten or more licensed employees does not apply to commissioned security officers or personal protection officers, and §35.162(f) says credits earned through outside entities may not be used for them. Scale does not buy an exemption here.

Inside the window the rule defines

§35.161(n) says continuing education is only valid if completed within the two-year period preceding the license’s current expiration date. The common shorthand, “you renew every two years”, describes a rhythm; the rule describes a boundary. Hours that land outside the boundary are not partial credit, they are no credit.

And The Document

Under §35.161(g) a commissioned security officer must submit a firearms proficiency certificate with the renewal application. This is a separate event from the classroom hours and needs its own slot in your calendar: our renewal enrollment covers the online training only, and the in-person firearms qualification is not included: you schedule it separately after finishing online. Officers assigned a shotgun should also read §35.146(b), which provides for a biennial familiarization of six rounds of “00” buckshot in connection with renewal of a commissioned security officer.

Four Things Officers Get Wrong Here

• “Unarmed officers need CE too.” They do not. §35.161(b) specifically exempts noncommissioned security officers. If you hold a Level 2 license and work unarmed, this requirement is not yours.
• “Level 4 is a promotion above Level 3.” It is not a grade. Level 4 is the personal protection officer credential and Level 3 is the commissioned security officer credential. Two distinct licenses that share one renewal pathway.
• “The school keeps my certificate, so I am covered.” §35.161(m) requires the attendee to keep certificates of completion for two years and furnish copies to the department on request.
• “A long lapse just means paying late.” 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. Often meaning the full Level 3 course rather than a renewal.

On the certificate itself: ours is listed as PSP 31, and §35.162(b)(3) describes what a compliant one carries. Your name and license number, the date of attendance, the number of hours, the courses attended, signed and dated by the school director, with the school holding its own records for two years. One further provision is worth knowing about in a metro with a large veteran workforce: §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 them.

The full text of these provisions is public at 37 TAC Chapter 35, and license status and applications are handled by the Texas DPS Private Security Bureau. Everything we teach is listed on our classes page.