Texas TDLR Mold Assessor vs Remediation Contractor License

Why this matters

Texas regulates mold-related services under Occupations Code Chapter 1958, administered by the Texas Department of Licensing and Regulation. Texas has the most layered mold-licensing scheme in the country: it splits Assessor and Remediator further into Technician, Specialist, and Consultant tiers, and the wrong tier on the wrong project produces enforcement exposure and an unpaid insurance loss. Out-of-state contractors who picked up a single Florida or New York license assume Texas will follow the same Assessor/Remediator binary. It does not. This article walks the tier structure and renewal.

Texas tier structure

Texas Occupations Code Chapter 1958 and the implementing rule 16 TAC Chapter 78 define six license categories. Three are on the assessment side, three are on the remediation side.

Assessment side:

• Mold Assessment Technician (MAT). Field-level data collection only. Can collect samples and document conditions, but cannot write a remediation protocol or sign a post-remediation verification report on their own authority. Works under a Mold Assessment Consultant.
• Mold Assessment Consultant (MAC). Can write the mold assessment report, develop the mold remediation protocol, and sign the post-remediation verification. The senior assessment-side credential.
• Mold Assessment Company (MACO). Business-entity license required for any firm that employs MATs or MACs to perform assessment work for compensation.

Remediation side:

• Mold Remediation Worker (MRW). Performs hands-on remediation labor. Works under a Mold Remediation Contractor.
• Mold Remediation Contractor (MRC). Supervises the project, signs the certificate of mold damage remediation, manages the workforce. The senior remediation-side credential.
• Mold Remediation Company (MRCO). Business-entity license required for any firm that employs MRWs or MRCs to perform remediation for compensation.

A firm doing both assessment and remediation needs both company licenses (MACO and MRCO) plus individual licenses for each individual performing the work, with the same conflict-of-interest restrictions that apply in New York and Florida.

Conflict of interest rule

Texas Occupations Code 1958.154 prohibits the same person or company from acting as both the assessor and the remediator on the same project, with one exception: residential property under specific scope thresholds where the consumer signs a disclosure form prescribed by TDLR. The form must be signed before assessment work begins. The TDLR disclosure form is updated periodically and the current revision must be used. A consumer-signed earlier-revision form is sometimes treated as non-compliant on audit.

Insurance carriers in Texas generally will not pay a mold loss where the assessment and the remediation came from the same firm without the conflict-of-interest disclosure on file. This is the single most common reason for a Texas mold-loss denial.

License qualification requirements

MAT (entry-level assessment):

• 24 hours of TDLR-approved training
• Examination administered by Pearson VUE
• No experience prerequisite

MAC (senior assessment):

• 40 hours of approved training plus three years of documented mold-related work experience, OR an approved degree plus one year of experience
• Examination
• The training requirement is on top of the MAT prerequisite if upgrading from MAT

MRW (entry-level remediation):

• 24 hours of approved training
• Examination
• No experience prerequisite

MRC (senior remediation):

• 40 hours of approved training plus three years of documented remediation experience, OR an approved degree plus one year
• Examination

MACO and MRCO (company licenses) require a designated responsible person who holds the MAC or MRC respectively, plus a business-entity application with a current Certificate of Filing from the Texas Secretary of State.

Renewal cycle

All Texas mold licenses renew annually. CE requirements vary by tier:

• MAT and MRW: 8 CE hours per renewal year
• MAC and MRC: 16 CE hours per renewal year, with at least 1 hour in laws and rules and 1 hour in workplace safety per renewal
• MACO and MRCO: no individual CE; the firm must maintain at least one currently-licensed designated responsible person

TDLR fees for individual licenses ran in the 100 to 300 dollar range per renewal cycle depending on tier on the 2024 schedule set under 16 TAC Chapter 78. Verify against the current TDLR fee schedule; the commission re-sets these by rule. Company license fees are higher.

Late renewal: TDLR allows a late-fee renewal up to 90 days past expiration. Beyond 90 days the license is delinquent and the licensee cannot perform regulated work until renewal is complete. Beyond 18 months past expiration the license is canceled and the individual must re-apply and retest.

Insurance and bonding

Texas Occupations Code 1958.155 requires general liability insurance with a minimum 1 million dollars per occurrence and 2 million dollars aggregate, with mold-specific coverage. A standard CGL with the mold exclusion intact does not meet the requirement. The TDLR Form CMP-1 certificate of insurance must list TDLR as a certificate holder.

Workers compensation coverage is not statutorily required for sole proprietors but is required for firms with employees, and TDLR audits will look for the policy.

The five-day notification rule

Texas Occupations Code 1958.152 requires the mold remediator to notify TDLR at least five days before the start of remediation on any project where the affected area exceeds 25 contiguous square feet. The notification is filed through the TDLR online system and includes the property address, the assessor's name and license number, the remediator's name and license number, and the estimated start and completion dates.

Missing the five-day notification is the second most common Texas mold enforcement finding. Plan the start date with the notification in mind, not the other way around.

Certificate of Mold Damage Remediation

At project completion the MRC signs the Texas Certificate of Mold Damage Remediation (TDLR Form CMDR). This certificate is given to the property owner and is required by Texas Property Code Section 27.007 to be disclosed by the homeowner on any future sale of the property within five years.

The certificate is not optional. Insurance carriers in Texas will hold the mold-loss payment until the certificate is delivered. Title companies will reject a real estate transfer that misses a required CMDR disclosure.

Compliance edges to watch

The tier structure and the two filing deadlines above are the obvious traps. These are the ones that catch experienced firms.

Scope that grows past the threshold mid-project. A job bid under the small-area threshold that opens up into a larger affected area is now a different job: notification, protocol, and licensing obligations attach to what the project actually is, not to what it was quoted as. Stop, re-scope, file, and restart. The temptation to keep working because the crew is already on site is exactly where the enforcement case comes from.

Deviating from the assessor's written protocol. The remediation is supposed to execute the protocol the consultant wrote. Field conditions routinely differ from what the protocol anticipated. The compliant response is a written protocol amendment from the assessor, not a verbal agreement on site and a note in your own file.

Blurring the assessment and remediation lanes. Beyond the formal conflict-of-interest rule, watch the informal version: a remediation contractor who "takes a few samples," writes the scope, and then verifies their own work has stepped across the line even if the paperwork says otherwise. Keep the roles clean and keep the correspondence clean, because the correspondence is what gets read later.

Unlicensed people on site. Everyone performing regulated work needs their own license, including day labor, temporary help, and subcontracted crews. The licensed firm carries the exposure for anyone it puts inside the containment.

Company license lapse behind current individual licenses. The firm's entity license and the designated responsible person are separate from each individual's card. A firm whose responsible person leaves is not licensed the day they leave, regardless of how many licensed technicians remain on payroll.

Advertising, signage, and vehicle lettering. Texas has requirements about how licensed mold services are held out to the public. Verify the current rule and put the license number where the rule says it goes; this is an easy administrative finding for an investigator who has not even seen a job site.

Records and retention. Assessment reports, protocols, notifications, daily logs, sampling data, chain-of-custody forms, the certificate, and the signed conflict-of-interest disclosure all have to be produced on audit. Keep them for the full period the rule requires, keep them per project, and keep them where someone other than the project manager can find them.

Consumer disclosure timing. Where a disclosure form is required, it is signed before the work it covers begins. A form signed at the end of the project, or on a superseded revision, is treated as not obtained.

Assuming another state's license means anything here. Texas does not treat an out-of-state mold credential as a substitute. Plan the licensing runway before you accept the work, not after.

When any of these is genuinely ambiguous on a specific project, ask TDLR in writing and keep the answer in the file. A documented question is a defense; an assumption is not.

References

• Texas Occupations Code Chapter 1958 (Mold Assessors and Remediators).
• 16 Texas Administrative Code Chapter 78 (Texas Department of Licensing and Regulation Mold Assessors and Remediators).
• Texas Property Code Section 27.007 (Certificate of Mold Damage Remediation disclosure).
• ANSI/IICRC S520-2024 Standard and Reference Guide for Professional Mold Remediation.
• Texas Department of Licensing and Regulation, Mold Assessors and Remediators Program guidance documents.