Effective June 8, 2023, the Texas Jobs, Energy, Technology and Innovation (JETI) Act established a new state-level property tax incentive designed to attract large-scale, capital-intensive investments in manufacturing, energy, and technology. The program provides a 10-year limitation on a school district’s maintenance and operations (M&O) property tax appraised value for eligible new facilities.
To qualify, projects must meet minimum investment and job creation thresholds ranging from $20 million and 10 jobs in smaller counties to $200 million and 75 jobs in larger counties, while also paying at least 110% of the county’s average wage and providing health benefits.
Eligible industries include advanced manufacturing, dispatchable power generation, critical-infrastructure construction, and high-tech research and development (R&D) or equipment production. Non-dispatchable power generation and energy storage projects (such as solar and wind) are excluded. Companies locating in federal Qualified Opportunity Zones may qualify for enhanced benefits but must demonstrate that the JETI agreement was a compelling factor in their site-selection decision.
Why This Update Matters Now
Although the JETI Act became effective in mid-2023, 2025 represents a turning point for businesses evaluating Texas investment opportunities.
- New Application System: In June 2025, the Texas Comptroller of Public Accounts (CPA) migrated the JETI application process to its secure eSystems portal. All new and pending applications must now be submitted through this system, which locks submissions and requires formal written requests for edits.
- Active Agreements Emerging: The CPA has now published a list of executed JETI agreements, demonstrating the program’s move from policy to practice. Examples include Summit Next Gen LLC’s $1.7 billion Galena Park project and Brazos Midlands Processing LLC’s $185 million natural gas facility.
- Proposed Rule Amendments: The Texas Taxpayers and Research Association (TTARA) published proposed rule updates in September 2025, following increased legislative attention and several major project filings.
- High-Profile Investments: Companies such as ExxonMobil and Eli Lilly have recently filed or announced major Texas projects reportedly evaluating or seeking JETI incentives—totaling billions in proposed investment statewide.
Together, these developments make this an ideal moment for companies to revisit JETI eligibility, compliance, and strategic fit before the next legislative session, when potential amendments could reshape the incentive landscape.
JETI vs. Chapter 313: Key Changes
Replacing the former Chapter 313 framework, JETI introduces a more accountable, transparent, and performance-based approach:
- Industry Eligibility: Limited to specific NAICS codes; data centers and non-dispatchable renewables excluded.
- Job Requirements: Only dispatchable power generation projects may qualify for job waivers.
- Wage Standards: Minimum of 110% of the county’s average wage, with required health benefits.
- Performance Bond: Required at 10% of the estimated 10-year tax benefit.
- Expanded Oversight: The Governor’s Office now joins the CPA and school district as approval authorities.
- Bonus Incentive: Up to a 25% enhancement for projects in Qualified Opportunity Zones.
- Compelling Factor Test: Applicants must demonstrate that the incentive directly influenced their Texas site decision, supported by evidence such as competing site offers or internal records.
How Ryan Can Help
With active agreements now in place, evolving administrative rules, and a new digital application process, JETI is entering its operational phase. Ryan’s Credits and Incentives experts continuously monitor these updates and can assist with:
- Evaluating JETI eligibility and competitiveness
- Preparing compliant eSystems portal submissions
- Addressing unfavorable recommendations or CPA follow-ups
- Managing compliance obligations for executed agreements
Whether planning a greenfield development or an expansion, Ryan can help organizations navigate Texas’s evolving property-tax incentive environment to maximize potential benefits.
Looking Ahead
This article is the first in a three-part series exploring Texas business incentives in advance of Ryan’s February 2026 webinar.
Future installments will cover:
- Uncovering overlooked Texas incentive mechanisms, and
- Texas Enterprise Zone Program updates for the new biennium
Stay tuned for upcoming releases and webinar registration details.
For more information, contact Ryan’s Credits and Incentives team.
TECHNICAL INFORMATION CONTACTS:
Sharon Roberts
Principal
Ryan
512.476.0022
sharon.roberts@ryan.com
Melissa Munoz
Principal
Ryan
505.312.4665
melissa.munoz@ryan.com
Omar Kahn
Director
Ryan
972.934.0022
omar.kahn@ryan.com
The material presented in this communication is intended to provide general information only and should solely be seen as broad guidance and not directed to the particular facts or circumstances of any individual who may read this publication. No liability is accepted for acts or omissions taken in reliance upon the content of this piece. Before taking (or not taking) any action, readers should seek professional advice specific to their situation from Ryan, LLC or other tax professionals. For additional information about this topic, please contact us at info@ryan.com.
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- Sharon M. Roberts
- Melissa Munoz