Most Texas transaction coordinators are not licensed real estate agents. That's legal — but only within limits that are written into the Texas Administrative Code (TAC) and the Texas Occupations Code, not just brokerage custom. This guide covers the licensing line specifically: what an unlicensed TC can do without triggering a license requirement, what crosses into brokerage activity that only a license holder may perform, and the exact rule citation behind each line. For the day-to-day workflow of the TC role itself, see What Does a Transaction Coordinator Do in Texas? For how AI changes what gets automated on the unlicensed side, see AI Transaction Coordinator for Texas Agents. This page describes what the statute and TREC rules say. It is not legal advice. A broker who is unsure whether a specific TC arrangement crosses the line should confirm with a Texas real estate attorney or TREC directly — the consequences below apply to both the unlicensed person and the sponsoring broker.
The base rule: license required to act as a broker or sales agent
Texas Occupations Code § 1101.351(a) is the starting point: "Unless a person holds a license issued under this chapter, the person may not act as or represent that the person is a broker or sales agent." What counts as acting as a broker is defined in § 1101.002(1)(A) — a person who, for compensation or the expectation of compensation, performs any of a list of acts including: selling, exchanging, or leasing real estate; negotiating or attempting to negotiate a listing, sale, exchange, purchase, or lease; listing real estate; procuring or assisting in procuring a prospect or property to effect a transaction; or providing a written price analysis or opinion tied to a property's actual or potential management, acquisition, disposition, or encumbrance. A TC's job description is built entirely around staying outside that list.
What an unlicensed TC can do
None of the following requires a real estate license, because none of it is negotiation, listing, procuring a prospect, or showing property:
- Scheduling. Coordinating inspection appointments, closing dates, walk-throughs, and calendar logistics between the parties and third parties (title, lender, inspector).
- Document collection and routing. Gathering executed contracts and addenda, sending documents for signature, confirming receipt, organizing the file.
- Status updates. Relaying factual status — "the title commitment arrived," "the survey is scheduled for Thursday" — without characterizing, advising on, or negotiating around what that status means for the deal.
- Deadline tracking. Calculating and monitoring TREC contract deadlines (option period, earnest money, financing, title, closing) and flagging what's coming due.
- Confirming already-advertised facts. 22 TAC § 535.5(g) specifically exempts "an answering service or clerical or administrative employees identified to callers as such to confirm information concerning the size, price, and terms of property advertised" from licensure. The limiting word is advertised — this covers restating what's already public (the listed price, the advertised square footage, the stated terms), not negotiating, estimating, or discussing anything not already publicly stated.
What crosses the line into licensed brokerage activity
Negotiating price, terms, or repairs
§ 1101.002(1)(A)(iii) makes "negotiates or attempts to negotiate" the sale, purchase, lease, or exchange of real estate a licensed-broker act. A TC relaying a party's already-stated position ("the seller says Thursday works for closing") is status reporting. A TC proposing terms, counter-offering, or telling a party what to accept is negotiating — and that's licensed activity regardless of the TC's title.
Showing the property
22 TAC § 535.4(c) states: "Unless otherwise exempted by the Act, a person must be licensed as a broker or sales agent to show a property. For purposes of this section, to 'show' a property includes causing or permitting the property to be viewed by a prospective buyer or tenant, unlocking or providing access onto or into a property for a prospective buyer or tenant, and hosting an open house at the property." That's a broad definition — unlocking a door for a buyer, letting an inspector in, or hosting an open house all fall inside it. (§ 535.4(d) carves out a narrow exception for unescorted prospective tenant access to a vacant rental, but only with access-control/ID verification and a specific written owner consent in 12-point bold — it doesn't extend to buyers or occupied property, and it doesn't create a general TC exception.)
Directing or supervising licensed activity
22 TAC § 535.4(e): "The employees, agents, or associates of a licensed broker must be licensed as brokers or sales agents if they direct or supervise other persons who perform acts for which a license is required." An unlicensed TC can be told what to do by a licensed agent or broker — but can't be put in the position of directing or supervising an agent's licensed activity, because that directing role itself becomes a licensed act.
Discussing property condition or pricing beyond what's advertised
The flip side of § 535.5(g)'s narrow clerical exemption: once a conversation moves past confirming already-advertised size/price/terms into opinion, negotiation room, or condition detail not already public, it's outside the clerical exemption and back inside licensed territory (negotiation under § 1101.002(1)(A)(iii), or a price opinion under § 1101.002(1)(A)(xi)).
Handling trust account funds
22 TAC § 535.146(c)(7): "A broker may only authorize another license holder to withdraw or transfer money from any trust account, but the broker remains responsible and accountable for all trust money received by that broker and all deposits to or disbursements from the trust account." An unlicensed TC can track that earnest money was delivered and confirm the receipt exists — but can't be the person authorized to move money in or out of a brokerage trust account.
What it costs to get this wrong
Two separate consequences apply, to two different people:
| Who | Exposure | Citation |
|---|---|---|
| The unlicensed TC | Criminal offense — Class A misdemeanor | Occ. Code § 1101.758(a)-(b): "A person commits an offense if the person acts as a broker or sales agent without holding a license under this chapter... An offense under this section is a Class A misdemeanor." |
| The sponsoring broker | Grounds for license suspension or revocation — paying an unlicensed person for licensed work | Occ. Code § 1101.652(b)(11): pays or splits a commission or fee "with a person other than a license holder." |
| The sponsoring broker | Grounds for license suspension or revocation — structuring the role itself | Occ. Code § 1101.652(b)(26): "establishes an association by employment or otherwise with a person other than a license holder if the person is expected or required to act as a license holder." |
The broker-exposure provisions matter as much as the misdemeanor. It's not just the unlicensed TC who's at risk if the arrangement crosses the line — it's the broker's own license, for paying the TC as if for brokerage work or for building a role that functionally requires one.
Licensed TCs have more room — but still operate under their broker
Some Texas TCs are licensed sales agents or brokers themselves. A licensed TC can negotiate, show property, and handle the fuller range of brokerage activity — but still operates under a sponsoring broker's supervision and the broker's authorized scope for that TC's role, per the broker-responsibility rules covered in the TC role guide. Being licensed removes the Occupations Code / TAC ceiling described above; it doesn't remove the broker's oversight.