TRAIGA Is Six Months Old. No Enforcement Actions — But the Machinery Is Being Built.

Six months after TRAIGA took effect, there are no publicly reported enforcement actions. But quiet is not the same as dormant.

The Texas Attorney General’s office has been building its TRAIGA enforcement infrastructure since the law was signed in June 2025 — staffing up, developing technical capacity, and training state-agency personnel on disclosure obligations. The statute requires the AG’s public complaint portal to be live by September 1, 2026 — and it may already be accepting complaints — so the quiet period could be brief.

How enforcement actually works

The path from consumer grievance to civil penalty has five steps.

A consumer files a complaint through the AG’s online portal. The AG may then issue a civil investigative demand (CID), requiring the company to hand over AI system descriptions, training-data categories, performance metrics, known limitations, and post-deployment monitoring records. If the AG finds a violation, the entity gets a notice and a 60-day window to cure it and submit a written explanation. If that window closes without resolution, the AG seeks civil penalties in court.

There’s a catch in those 60 days. Norton Rose Fulbright attorneys Marc Collier and Ethan Glenn noted in March 2026 that the period “may be insufficient time to ‘cure’ a violation of TRAIGA, particularly because a ‘cure’ might mean that the party must substantially modify an AI system.” In practice, a notice of violation can land like a cease-and-desist.

The penalty tiers

TRAIGA’s civil penalties are tiered, not flat. Curable violations carry $10,000–$12,000 each. Uncurable ones jump to $80,000–$200,000. Continuing violations accrue at $2,000–$40,000 per day.

What separates curable from uncurable isn’t settled. The statute doesn’t define it; Norton Rose Fulbright expects the line to be “developed by experts, the courts and the resulting common law.” That uncertainty cuts both ways — companies have less guidance, but so does the AG.

Paxton’s pre-TRAIGA track record

AG Ken Paxton is not new to AI-adjacent enforcement. In 2024, his office launched investigations into Character.AI, Reddit, Instagram, and Discord over children’s privacy and safety concerns, and stood up a specialized data-privacy enforcement team.

That history suggests both the appetite and the infrastructure to act. Whether TRAIGA enforcement opens with a high-profile target or a quiet CID to a lesser-known company is anyone’s guess — but the portal opening this fall hands consumers a direct channel to the AG’s desk. DIR rulemaking under TRAIGA, meanwhile, is still developing; no formal agency guidance has been confirmed as published.