Across Texas, churches and synagogues are wrestling with a pressing question: how do you keep congregations safe without crossing the line into law enforcement? Recent updates to state law and DPS regulations have carved out a unique space for volunteer security teams, ordinary members of faith communities who step forward to protect their own. From the Private Security Act’s volunteer exemption to Senate Bill 694’s civil immunity protections, and the rules surrounding concealed carry in places of worship, these measures shape what armed volunteers can and cannot do. For leaders, volunteers and congregants, understanding this legal framework is helpful to building safety teams that are both effective and compliant.
1. Texas Occupations Code – Private Security Act (Chapter 1702)
- General Rule: Anyone providing security services for compensation must be licensed through DPS’s Private Security Program.
- Volunteer Exception: Churches, synagogues, and other houses of worship may use volunteer safety/security teams without requiring DPS licensing, provided they are unpaid and serve only their own congregation.
- HB 1133 (2023 Update): Explicitly exempts volunteer church security from licensing requirements.
2. Texas DPS – Armed Security Volunteers
- Firearms Regulation:
- Volunteers carrying firearms must individually comply with Texas License to Carry (LTC) requirements.
- DPS does not issue “security licenses” for unpaid volunteers; they carry under their personal LTC authority.
- Restrictions:
- Volunteers cannot present themselves as licensed “security officers” unless they hold a DPS license.
- They cannot wear uniforms, badges, or insignia that imply law enforcement or licensed security status.
- Churches must avoid advertising volunteers as “security guards” to remain within the exemption.
- Training: DPS strongly encourages—but does not mandate—firearms and situational training for volunteers. Many churches adopt DPS-aligned training standards to reduce liability.
3. Senate Bill 694 (2023) – Civil Immunity
- Provides civil immunity for churches and their designated security volunteers acting within the scope of their duties.
- Applies to both armed and unarmed volunteers, provided they are serving their own congregation.
- Protects the organization from lawsuits arising from good-faith security actions.
Under SB 694, civil immunity for LTC volunteers is tied to narrowly defined duties:
- Responding to imminent threats in self-defense.
- Acting within roles assigned by the congregation.
- Not assuming law enforcement powers or proactive enforcement authority.
- Training must go beyond LTC basics to prepare for dynamic, high-risk scenarios.
Scope of Duties – LTC Volunteer Security Under SB 694
Civil Immunity Framework
- SB 694 grants civil immunity to churches and their designated volunteers when acting within the scope of their duties.
- This immunity is not blanket protection—it applies only when volunteers act in good faith and within the boundaries of lawful self-defense.
- The law is designed to encourage congregations to organize volunteer teams without fear of lawsuits, but it does not expand the authority of volunteers beyond what is already permitted under Texas law.
What “Scope of Duties” Means
- Reactive, Not Proactive:
- Volunteers may respond to imminent threats of violence (e.g., active shooter, assault).
- They are not authorized to proactively enforce laws, detain individuals, or act as police officers.
- Congregational Assignment:
- Duties must be defined by the church (e.g., monitoring entrances, observing suspicious behavior, assisting in evacuation).
- Immunity applies only when acting within those assigned roles.
- Self-Defense Doctrine:
- Volunteers may use force consistent with Texas Penal Code Chapter 9 (Use of Force in Defense of Persons).
- The LTC provides the legal right to carry, but use of force must meet the “reasonable belief of imminent harm” standard.
Limitations of Authority
- No Law Enforcement Powers:
- Volunteers cannot arrest, detain, or interrogate.
- They cannot present themselves as licensed “security officers” unless formally licensed under DPS.
- No Expanded Jurisdiction:
- Immunity applies only on the premises of the house of worship or affiliated property.
- No Civil Immunity for Negligence:
- Immunity does not cover reckless or negligent acts (e.g., mishandling a firearm, excessive force).
Training Expectations
- Beyond LTC Qualification:
- The LTC course covers firearm safety, legal basics, and marksmanship—but it does not prepare volunteers for dynamic, real-world threats.
- Recommended Training:
- Scenario-based active shooter response (movement, communication, cover/concealment).
- De-escalation and situational awareness (recognizing threats before they escalate).
- Coordination with law enforcement (handoff procedures, communication protocols).
- Medical response training (tourniquet use, trauma kits)
- Best Practice: Churches should adopt a formal training program for volunteers to ensure defensible readiness and reduce liability.
Practical Example of Scope
- Within Scope:
- A volunteer observes an armed assailant entering the sanctuary and uses their LTC firearm to stop the threat.
- A volunteer assists congregants in evacuation during an emergency.
- Outside Scope:
- A volunteer detains a disruptive but nonviolent individual.
- A volunteer conducts bag searches or patrols off church property.
- A volunteer uses force without imminent threat.
4. Texas Penal Code – Firearms in Places of Worship
- Default Rule: LTC holders may carry in churches unless the congregation posts proper 30.06/30.07 signage prohibiting firearms.
- Church Policy: Each house of worship may set its own rules on whether armed volunteers are permitted.
- Liability: If armed volunteers are allowed, the church assumes responsibility for oversight, training, and insurance coverage.
Compliance Checklist for Texas Houses of Worship Security Volunteers
| Requirement | Unarmed Volunteers | Armed Volunteers | Paid/Contracted Security |
|---|---|---|---|
| DPS Security License | Not required | Not required (if unpaid) | Required |
| LTC / Firearm Permit | N/A | Required | Required |
| Uniforms/Badges | Not permitted | Not permitted | Permitted if licensed |
| Civil Immunity (SB 694) | Yes | Yes | No (treated as professional security) |
| Church Oversight | Required | Required | Required |
| Liability Insurance | Recommended | Strongly recommended | Required by DPS |
Bottom Line
- Unpaid volunteers in Texas houses of worship are exempt from DPS security licensing.
- Armed volunteers must carry under their personal License to Carry (LTC) and cannot present themselves as licensed security.
- Civil immunity (SB 694) protects congregations and volunteers acting in good faith.
- Paid or contracted security must be licensed through DPS.