Effective September 1, 2025

Texas SMBs: Protect Your Business from Punitive Damages

Texas SB 2610 creates a "safe harbor" for businesses with fewer than 250 employees. Demonstrate cybersecurity compliance and shield your business from punitive damages in data breach lawsuits.

Safe Harbor Protection
What you get with compliance

Protection from Punitive Damages

Avoid 2-4x multipliers on breach damages

Legal Defense Documentation

Evidence package for court proceedings

Tiered Requirements

Simplified compliance for smaller businesses

Industry-Standard Frameworks

CIS Controls, NIST CSF, ISO 27001 alignment

Understanding the Law

What is Texas SB 2610?

Senate Bill 2610, also known as the Texas Cybersecurity Safe Harbor Act, was signed into law by Governor Greg Abbott on June 20, 2025. It adds Chapter 542 to the Texas Business and Commerce Code, creating a legal shield for small and mid-sized businesses that take cybersecurity seriously.

An Affirmative Defense

SB 2610 operates as an affirmative defense against punitive damages in data breach lawsuits. If your business suffers a breach but can prove it had a compliant cybersecurity program in place, the court cannot award punitive (exemplary) damages against you.

What It Protects

The law shields qualifying businesses from exemplary (punitive) damages only. Punitive damages are penalties imposed by courts to punish negligent behavior and can be2 to 4 times the amount of actual damages, potentially devastating a small business.

What It Does NOT Protect

The safe harbor does not provide immunity from all liability. Compensatory damages for actual losses can still be awarded. It also does not affect enforcement actions by the Texas Attorney General or other regulatory bodies.

Key Dates & Facts

Jun 20

2025

Signed into law by Governor Greg Abbott

Sep 1

2025

Law becomes effective across Texas

Ongoing

Annual

Must update program within 1 year of framework changes

Who Qualifies?

Texas businesses with fewer than 250 employees

Businesses that own or license computerized data containing sensitive personal information

Must maintain a documented cybersecurity program conforming to recognized frameworks

Program must include administrative, technical, and physical safeguards

Businesses under HIPAA, GLBA, or PCI DSS qualify if in full compliance

The Threat is Real

Why Texas SMBs Need This Protection

Small and mid-sized businesses are increasingly targeted by cybercriminals, yet many lack the resources for comprehensive security programs. SB 2610 levels the playing field.

43%

of all cyber attacks target small businesses

$165

average cost per compromised record (IBM 2024)

60%

of small businesses close within 6 months of a breach

2-4x

punitive damages multiplier that safe harbor eliminates

Following Ohio & Utah's Lead

Texas joins Ohio (2018) and Utah (2021) in enacting cybersecurity safe harbor legislation. In both states, these laws have driven a significant increase in cybersecurity investment by SMBs, proving that incentive-based approaches work better than punitive mandates alone.

Unlike traditional regulations that impose penalties for non-compliance, SB 2610 takes areward-based approach: do the right thing, and the law will protect you.

The Real Cost of Inaction

Consider a Texas business with 50 employees and 10,000 customer records. Without safe harbor protection, a data breach could result in:

Compensatory damages~$1.65M
Punitive damages (2.5x)~$4.1M
Total potential liability~$5.75M
With safe harbor~$1.65M (no punitive)
Recognized Frameworks

Which Cybersecurity Frameworks Qualify?

SB 2610 requires your cybersecurity program to conform to an industry-standard framework. The specific framework depends on your business size and industry.

NIST Cybersecurity Framework
National Institute of Standards and Technology

The gold standard for cybersecurity risk management. Covers Identify, Protect, Detect, Respond, and Recover functions. Recommended for Tier 3 businesses (100-249 employees).

CIS Controls
Center for Internet Security

Prioritized set of cybersecurity best practices. Implementation Group 1 (IG1) is specifically designed for small businesses and is the baseline for Tier 2 (20-99 employees).

ISO/IEC 27001
International Organization for Standardization

International standard for information security management systems (ISMS). Widely recognized globally and accepted for Tier 3 compliance under SB 2610.

Already Regulated?

If your business is already subject to HIPAA (healthcare), GLBA (financial services), or PCI DSS (payment card processing), you may already qualify for safe harbor protection. Full compliance with these existing regulatory frameworks satisfies SB 2610's requirements. Our assessment can help verify your compliance status.

How Texas SB 2610 Works

The law creates three compliance tiers based on your company size, making it easier for smaller businesses to qualify.

Tier 1
Simplified
For businesses with fewer than 20 employees
  • Unique passwords for all accounts
  • Multi-factor authentication
  • Annual security training
  • Regular data backups
Est. Time:15-20 minutes
Tier 2
Moderate
For businesses with 20-99 employees
  • All Tier 1 requirements
  • CIS Controls IG1 compliance
  • Asset inventory management
  • Vulnerability management
Est. Time:30-45 minutes
Tier 3
Comprehensive
For businesses with 100-249 employees
  • All Tier 1 & 2 requirements
  • Full framework compliance
  • NIST CSF, ISO 27001, or SOC 2
  • Formal security governance
Est. Time:45-60 minutes
ROI Calculator

Calculate Your Potential Savings

See how much safe harbor protection could save your business in the event of a data breach.

Your Business Profile
Adjust the sliders to match your business
50
150100150200249
$5.0M
$100K$10M$25M$50M
10,000
10025K50K100K
Your Compliance Tier

Tier 2 - Moderate

Without Safe Harbor
Compensatory Damages$1.5M
Potential Punitive Damages$3.8M
Total Potential Liability$5.3M
With Safe Harbor
Compensatory Damages Only$1.5M
Punitive Damages$0 (Protected)
Maximum Liability$1.5M

Your Potential Savings

$3.8M

Est. Compliance Cost

$8K/year

ROI

7400%

Frequently Asked Questions

What is Texas SB 2610?

Texas SB 2610, also known as the Texas Cybersecurity Safe Harbor Act, is a law that provides protection from punitive (exemplary) damages in data breach lawsuits for Texas businesses that maintain a compliant cybersecurity program. It becomes effective September 1, 2025.

Who qualifies for safe harbor protection?

Texas businesses with fewer than 250 employees that handle sensitive personal information and maintain a cybersecurity program that conforms to recognized frameworks (like NIST CSF, CIS Controls, or ISO 27001) may qualify for safe harbor protection.

What damages does safe harbor protect against?

Safe harbor protects against exemplary (punitive) damages only. Compensatory damages for actual losses can still be awarded. It also does not affect enforcement actions by the Texas Attorney General.

How do I prove compliance if there's a breach?

You need to demonstrate that your cybersecurity program was in place at the time of the breach. Our Safe Harbor Documentation Package generates a comprehensive evidence binder with timestamps that you can use in legal proceedings.

Do I need to update my program when frameworks change?

Yes, the law requires you to update your cybersecurity program within one year of any updates to the framework you're following (e.g., NIST, CIS Controls). We'll notify you when updates are released.

What if I have more than 250 employees?

Businesses with 250 or more employees are not covered by this safe harbor provision. However, maintaining a strong cybersecurity program is still essential for risk management and may provide other legal benefits.

Ready to Protect Your Business?

Take the first step toward safe harbor protection. Our free assessment takes just 15-45 minutes depending on your company size.