TCOT — CA→TX Certification & Registration Research

🚨 TWO CRITICAL FINDINGS

1. MXU must register as a foreign entity in Texas IMMEDIATELY. This is the longest lead-time item (~2-3 weeks for the full chain) and a prerequisite for CMBL vendor registration. Cost: ~$750 + $100-300/yr registered agent.

2. Texas HUB certification for minority/women-owned businesses NO LONGER EXISTS. As of Dec 2, 2025, the program was replaced with VetHUB (service-disabled veterans only, 20%+ disability). All race/ethnicity/sex-based certifications were revoked. MXU cannot get HUB/VetHUB certification.

Action Items Summary

Good News: No Professional Certification Needed

Step	Priority	Timeline	Cost
1. Register as foreign entity (TX Secretary of State)	🔴 Critical	1-2 weeks	~$750
2. Confirm franchise tax account is Active	🔴 Critical	Automatic after #1	$0
3. Register on CMBL (vendor list)	🟡 High	Few days after #2	$70/yr
4. Appoint TX registered agent	🔴 Critical (part of #1)	Immediate	~$100-300/yr
5. TX sales tax permit	🟢 Low (likely not needed)	1-2 weeks	Free
6. HUB/VetHUB certification	❌ Not available	N/A	N/A

Marketing/advertising/creative services are unregulated professions in both CA and TX. No professional license or certification exists, and no reciprocity issue applies. MXU can bid on and perform TX state marketing contracts without any professional license.

Foreign Entity Registration (Critical Path)

Under Texas Business Organizations Code § 9.001, a CA LLC or corporation doing business in Texas must register as a foreign entity.

File: Application for Registration with TX Secretary of State
Online: sos.state.tx.us
Fee: ~$750
Requires: TX registered agent appointment, good standing in CA
Triggers: Automatic franchise tax account (must maintain "Active" status)
Annual: Public Information Report + Franchise Tax Report (may owe $0 if under ~$2.47M threshold, but MUST file)

CMBL Registration (Texas Vendor List)

Centralized Master Bidders List — master vendor database used by TX state purchasing entities.

Prerequisites: Federal EIN + Active TX franchise tax status
Portal: comptroller.texas.gov/purchasing/vendor/cmbl/
NIGP Codes: 915-00 (Advertising), 918-00 (PR), 915-66 (Marketing/Comms), 962-00 (Graphic Design), 920-00 (Consulting)
Fee: $70/year
Service area: Select "statewide" for TCEQ work

No Reciprocity Between CA and TX

Zero reciprocity between CA and TX for business registration, vendor registration, or professional licenses. Everything must be done independently in Texas. CA registration and CaleProcure/DGS vendor status carry no weight in TX.

HUB → VetHUB Change (Dec 2, 2025)

The Texas Comptroller eliminated the traditional HUB program via emergency rules and replaced it with VetHUB:

VetHUB: Only available to service-disabled veterans (20%+ disability, 51%+ ownership)
All prior HUB certifications based on race, ethnicity, or sex were revoked
Reason: Executive orders from President Trump and Governor Abbott banning DEI in government procurement
Legal status: Legally contested — Comptroller may have overstepped by overriding a legislatively-created program
MXU impact: Cannot get VetHUB. Being minority/woman-owned provides no formal TX procurement advantage.

Alternatives: Federal SBA 8(a), WOSB, or NMSDC MBE certifications can be referenced qualitatively in proposals but carry no TX state procurement weight.

Sales Tax

Likely not required. Pure marketing/creative/strategic services are generally not taxable in Texas. Additionally, TCEQ as a government entity is sales tax exempt. A permit is free to obtain as a precaution.

Research date: March 27, 2026. Consult a Texas business attorney for definitive legal advice on foreign entity registration and tax obligations.

CA → TX Registration Research