The Texas Board of Professional Engineers and Land Surveyors publishes every formal disciplinary action it takes. The documents sit two clicks from the agency home page, one PDF per board meeting, going back to November 2023. They are short, plainly written, and free.
They are also easy to overlook. That is strange, because they are the clearest available statement of what a licensing board will actually act on, written by the board itself, with no interpretation in between.
So we pulled all twelve and read every entry.
What is in the file
Twelve board meeting documents are posted, from November 9, 2023 through August 13, 2026. The agency states its retention policy on the same page: closed enforcement cases are posted for three years past the closing date. So this is a rolling three-year window, not an archive.
Across those twelve documents there are 71 separate actions. Three of the 71 carry more than one case number, because several complaints were consolidated into a single order. We counted the action, not the case number.
The 71 break down like this:
- 32 involve a licensed professional engineer
- 22 involve a registered professional land surveyor
- 17 involve an unlicensed person or an unregistered firm
That last group is worth a sentence. Close to a quarter of this published record is not discipline at all in the usual sense. It is telling a homebuilder, a consulting company, or an individual with no license that they cannot do what they have been doing. Those cases end in cease and desist orders.
We are not naming the licensees in this piece. Every order is public and every case number cited below is verifiable in the source documents, which are linked at the bottom. The pattern is the point, not the people.
The finding
Of the 32 actions involving a licensed engineer, 12 cite 22 Texas Administrative Code section 137.65, titled Action in Another Jurisdiction.
It was not a Texas project. It was not a Texas complaint. Another state's board acted first, and Texas followed.
Eleven of those twelve licensees have a mailing address outside Texas. North Carolina appears three times. Ohio, Minnesota, Maryland, Pennsylvania, Oregon, Illinois, Arizona and Florida appear once each. The twelfth has a Texas address and was disciplined in Texas for work done somewhere else.
That is 12 of 32. It is worth being careful about what kind of claim that is, because the obvious version of it is not true. Reciprocal discipline is not the biggest category of anything here. Section 137.63(b)(6), the general requirement to practice engineering in a careful and diligent manner, is cited in 12 engineer actions too, so at the level of individual subsections the two are tied. Widen the lens to whole rule sections and 137.63, engineers' responsibility to the profession, appears in 21 of the 32 and leads comfortably.
The finding is narrower and more specific than a ranking. Close to four in ten published Texas engineer actions did not begin with a Texas project. Six of the twelve cite both 137.65 and 137.63(b)(6), because the way Texas describes an imported case is to name the Texas rule the out-of-state conduct would have violated here.
Why that rule reaches so far
Section 137.65(b) does the work. It provides that a disciplinary action taken by another jurisdiction, on a matter that would violate the Texas Act or board rules, is sufficient cause for discipline in Texas, and that a certified copy of the other jurisdiction's order is sufficient evidence.
Texas does not have to reopen the engineering. It does not need a Texas complainant, a Texas project, or a technical consultant. It needs a certified copy of a document another board already signed.
The other half of the mechanism is in section 139.31(b), which says that all enforcement actions other than an informal reprimand are published and transmitted to the National Council of Examiners for Engineering and Surveying.
So the loop closes. Texas exports its orders into a shared record and imports everyone else's from the same place. NCEES runs a database for exactly this purpose, and its own instruction manual recommends that member boards review it monthly, specifically to find licensees who were disciplined in another jurisdiction and did not report it back home. The manual is candid about why the database exists at all: it is not realistic for every board to monitor every other board's newsletters and websites.
That is a recommendation to member boards, not a description of what any particular board does, and nothing in the public record here shows how often Texas acts on it. What the record does show is what happens when a licensee does not report.
The thirty day clock
Which brings up the rule that turns one order into two.
Section 137.5(c) requires a license holder to notify the board in writing not later than 30 days after a misdemeanor or felony criminal conviction, or after any sanction is imposed by another state's engineering licensing board.
Eight of the twelve reciprocal cases also cite 137.5(c). In each one, the board found out anyway, and the failure to say so became a second finding in the order.
The board's own suggested sanction for a reporting failure is a reprimand and a $150 administrative penalty. That is the lowest row in its suggested sanction table. The money is not the exposure.
The exposure is that the reporting failure is now a finding in a Texas order, which section 139.31(b) then transmits into the same shared record, where it is visible to every other board where the engineer holds a license. A missed notice in one state becomes a durable entry every other state can see.
What the underlying work actually was
Reciprocal discipline sounds like paperwork, and some of it is. Some of it is not, and the Texas orders describe the original conduct in detail.
One November 2024 order, case D-42934, recites that the engineer sealed inadequate design plans, used a facsimile signature rather than properly certifying the plans, lacked adequate technical knowledge of the software behind a post-tensioned concrete design, and sealed work not done under his direct supervisory control. Texas resolved it with a formal reprimand.
A second order from the same meeting, case D-42938, recites structural plans that cited incorrect building codes, floor framing that was under-designed or over-stressed, and shear walls inadequate for wind loads, plus civil plans that did not meet generally accepted standards, plus architectural services provided without an architecture license in that state. That one resolved as a one year probated suspension.
Both are Texas orders. Neither is about a Texas project.
The rules about the state of a document
A second group comes into view, and it is closer to home for anyone who touches a drawing set.
Three sealing rules turn up in ordinary orders, and none of them is about whether a calculation was right. Two of the three sit in Texas conduct findings. The third sits mostly in imported cases, as its own bullet says:
- Section 137.33(e). Preliminary documents must be marked as preliminary, with text stating the purpose for which they are being released, in place of the seal. A May 2026 order, case D-43193, is exactly this and nothing else: the engineer did not mark the set. It resolved as a formal reprimand with a $750 penalty.
- Section 137.33(f). The seal, signature and date go on the final version of the work before it leaves the engineer's control. Case D-43038 cites it alongside a careful and diligent finding.
- Section 137.37(a)(2). A license holder may not seal anything while a license is inactive, expired, revoked or suspended. It appears three times, and in two of the three the case was imported and the original conduct was practicing on an expired license in another state.
The board does not price those three the same way, and the schedule is worth opening, because the gaps inside this one group are enormous. The row covering 137.33(e) and (f), failure to sign, seal, date, or include firm identification on work, is a reprimand and $750. Two other rows in the same block are titled practice or affix seal with an expired or inactive license, at a one year suspension and $750, and practice or affix seal with a suspended license, at revocation and a $5,000 penalty. That last one is the same tier the schedule assigns to sealing work that endangers the public, and to gross negligence.
Read those row titles closely, because two of them cover practicing as well as sealing, so the top of that range is not purely a failure about a document. What the spread does still show is that the board's concern rises with the state of the license behind the seal rather than with how much of the drawing was wrong. An unmarked preliminary set is a labeling failure. A seal applied under a suspension is a claim of authority the engineer does not have.
What makes 137.33(e) worth noticing is that it is a labeling requirement on a set that is, by definition, not finished. It is not violated by a bad decision. It is violated by a set going out the door in the wrong state.
What the outcomes look like
Across the 32 engineer actions:
- 17 resolved as a reprimand
- 10 as a probated suspension
- 2 as an active suspension
- 3 as revocation
One of those two active suspensions is a hybrid, a two year suspension split into one year active and one year probated. We counted it as active, which is the more conservative reading of the two.
All three revocations were by operation of law following a felony sentencing, under section 139.43(a)(1) and Chapter 53 of the Occupations Code. None of the three was a finding about engineering work.
So more than half of the published engineer discipline in this window ends in a reprimand. Money is rarer still. Seventeen of the 32 engineer actions carried no administrative penalty at all, and of the 15 that did, 13 fell between $750 and $4,000. The board's schedule runs from a $100 minimum to a $5,000 statutory maximum per violation. One order here came to $5,035, and it cites four separate rules; the order itself gives no reasoning, so read the per-violation wording alongside it rather than as an explanation of it.
What this file does not tell you
This is the part that decides whether the rest of the piece is worth anything.
It is not the enforcement workload. The board states on its own overview page that it handles over 600 enforcement cases per year, and that over 69,000 professional engineers offer services in Texas. Seventy-one published actions across nearly three years is not the roughly 1,800 cases that implies. It is the small share that ends in a published order. The great majority close without one.
Informal reprimands are excluded by rule. Section 139.31(b) publishes everything except an informal reprimand. So the least serious tier of actual discipline is, by design, invisible here.
The window is not evenly filled. The three year retention policy means 2023 is represented by a single meeting, while 2024 and 2025 each have four. 2023 looks quiet because its earlier meetings aged off the site, not because less happened. We excluded 2023 from any year-over-year reading for that reason, and 2026 currently has three of its four meetings.
Dismissals never appear. This is a record of outcomes, not of allegations. Nothing here says anything about how often a complaint is filed and goes nowhere.
Put together, the honest statement of the finding is narrow. Among Texas engineer matters that reach a published board order, close to four in ten began with another state's order rather than a Texas project. That is a fact about published orders. It is not the claim that most engineering misconduct happens out of state, and this record cannot speak to that at all.
The practical reading
If you hold licenses in more than one state, the calendar that matters is not the one in the state where the project was. It is 30 days from the other board's order, running separately in every state where you are licensed. In eight of the twelve reciprocal cases here, the licensee did not report and Texas acted anyway.
The effect runs both directions. The same rule that publishes an order is the rule that transmits it. A resolution in one jurisdiction is an input everywhere else you practice.
The rest of it is quieter. More than half of these actions ended in a reprimand, and a real share of them came down to the state a document was in when it left the office: a preliminary set that nobody marked as preliminary, or a final set released before it carried the seal, signature and date the rule asks for. Those are not failures of judgment. They are failures of handoff, and they happen to careful people on busy weeks.
Setmark reads a plan set, resolves the builder's own standards, and marks on the drawings where the set does not meet them. It does not read seals, signature blocks, preliminary markings or title block state, so none of the failures above is something it looks for. It is not a licensed design professional, it does not replace a licensed review, and it has no role in what a board or an authority having jurisdiction decides.