Texas does not require a pest control surety bond. It requires liability insurance at published minimums, filed on one specific form — and it requires something most operators have never been told about their own policy: the care, custody and control exclusion has to be deleted.
That last requirement is the reason this post exists. The policy Texas wants is general liability, but not the version most operators are sold — and our Texas state page sets out the wider licensing and market picture. What follows is the filing, and one part of it is a coverage defect rather than a paperwork step.
What Texas asks for instead of a bond
The Texas Department of Agriculture Structural Pest Control Service requires all current commercial business licensees, and noncommercial certified applicators licensed through a noncommercial business license, to maintain insurance of not less than $500,000 bodily injury and property damage coverage with a minimum total aggregate of $1,000,000 for all occurrences — figures published by SPCS on its structural pest control business page, which is where to confirm them, since the department notes a transition in insurance minimums adopted by rule.
No bond appears anywhere in that requirement. The commercial business license fee is $300, published by SPCS on the same structural pest control business page, and you may not conduct business or advertise until the license is actually issued. That is a filing fee set by the department, not the cost of the insurance the licence requires.
The care, custody and control deletion
This is the part worth reading twice. Texas requires the insurance to cover liability for damage to persons or property under the licensee’s care, custody or control, and states directly that your insurance agent must be informed that the care, custody and control exclusion must be deleted, to conform to Chapter 1951.312 of the Texas Occupational Code.
Here is why that matters more than any limit. A standard general liability policy excludes damage to property in your care, custody or control. The logic is ordinary enough — property you have taken charge of is your responsibility, not a third party’s risk, and the insurer does not want to underwrite your workmanship.
Now apply it to pest control. The structure your crew is treating is, for the duration of the job, property in your care. A fumigation tent goes over a building you have taken control of. A soil treatment happens around a foundation you are working on. If the exclusion stands, the policy declines exactly the losses your trade produces, and the operator finds out at the worst possible moment.
Texas is the state that says so out loud. That does not mean the exclusion is harmless everywhere else — it means Texas made the fix a licensing condition. Ask your agent to confirm the deletion is endorsed on the policy, in writing, and keep the endorsement rather than the assurance.
The form is not a certificate
SPCS accepts proof of insurance on the ALS-1101 form and states that no other insurance form will be accepted.
That is worth flagging because a certificate of insurance — the document that satisfies most states, most landlords and most commercial customers — is not what Texas asked for. An operator who requests a certificate and files it has produced a perfectly valid document for the wrong purpose. Ask your agent for the ALS-1101 by name.
The narrowness is deliberate. A certificate is a summary prepared by a broker; a state-specified form is a declaration the insurer completes on the state’s terms, and it carries the confirmations Texas wants rather than the ones a broker template happens to include.
Where the bond idea comes from
Mostly from two directions. Operators who work across state lines carry the requirements of wherever they were licensed first, and the bond mechanism itself — a guarantee to somebody else, repaid by you — is unusual enough that it sticks in the memory more firmly than an insurance filing does. Texas asks for the filing. Some states do ask for both — Louisiana requires proof of both insurance and a bond for its place of business permit, which is why the Louisiana requirement reads so differently. And commercial contracts sometimes require one independently of any state, which is a real request even though Texas did not make it.
A request like that belongs with a surety underwriter, who will price it on your credit rather than your loss history. We do not place bonds and would rather tell you that in the first email than the fourth. What we can do is the ALS-1101 side of the same file.
What the state minimum does not reach
The published minimums are a floor for licensing, not a program for a business.
The aggregate is the number to watch rather than the per-occurrence figure. An aggregate is the total the policy will pay across a policy year, and a Texas operation running year-round routes in a long warm season has more occurrences per year than an operator in a state with a real winter. Two moderate claims and a third late in the year is not an unusual pattern, and it is how an aggregate gets consumed by losses that were individually unremarkable.
Applicator pollution liability answers what general liability is written to exclude — drift, overspray, misapplication, chemical release — which for fumigation work is the core exposure rather than an edge case. Commercial auto covers route trucks across some of the longest metro drives in the country, and workers compensation covers a crew working attics and crawlspaces in Gulf-coast heat.
If you issue wood-destroying-organism reports, professional liability answers the report itself — a deleted care, custody and control exclusion does nothing for an inspection opinion a buyer relied on. Equipment travels on its own form, contractors tools and equipment written as inland marine. And where commercial accounts stack limits, an umbrella sits above the primary layers.
Real-world scenario. A Houston operator files for a commercial business license with a general liability policy bought from a national quoting platform, at limits comfortably above the state minimum. The filing is rejected, and the reason is not the limits — it is that the policy carries a standard care, custody and control exclusion and the state requires it deleted. The operator has more insurance than Texas asked for and less coverage than Texas requires, which is a genuinely confusing position to be in and a completely ordinary one. The fix is an endorsement rather than a new policy. The lesson is that the licensing requirement was never really about how much coverage you bought; it was about whether the policy answers the losses this trade produces.
Commercial and noncommercial are different licences
Texas separates the two, and the distinction decides which requirements land on you at all.
A commercial business licence is what an operator providing services for hire holds, and it carries the insurance requirement and the fee. A noncommercial business licence covers an organisation applying pesticides on its own property or in its own facilities — a school district, a hospital system, a property owner treating its own buildings — and SPCS states there is no fee for it, though a complete noncommercial business licence application is still required.
The line that matters: a noncommercial licence may not be used to provide services for hire. An in-house maintenance team that starts treating a sister property under a different ownership entity, or doing a neighbouring business a paid favour, has quietly crossed into commercial territory with the wrong licence. It is a licensing question first and an insurance question immediately afterwards, because the coverage a noncommercial operation carries is rarely built for third-party work.
What to ask your agent, specifically
Three questions, none of which a quote comparison will answer on its own.
Is the care, custody and control exclusion deleted, and can I see the endorsement? Not “are we compliant” — the endorsement, by form number. An assurance is not a policy provision, and the person assuring you may not know Texas requires it.
Can you issue an ALS-1101 rather than a certificate? If the answer involves explaining that a certificate is equivalent, the agent has not done a Texas structural pest control filing before, which is worth knowing early rather than at the filing deadline.
What is the aggregate, and how much of it is already used? Mid-year, after a claim or two, the aggregate is the number that decides whether the policy still meets the state minimum. An operator can drift out of compliance without changing anything about the policy, simply by having had a year.
Getting the sequence right
For a Texas startup: bind the liability program, confirm in writing that the care, custody and control exclusion is deleted, request the ALS-1101 rather than a certificate, file it, and wait for the license before you advertise. For an established operation: check the endorsement is still on the policy whenever you change carriers, because a competitively priced replacement policy is exactly where the deletion silently disappears.
Texas runs a near year-round calendar with Gulf-coast termite pressure behind it, so the exposure never really pauses the way it does further north — worth reading alongside how a general pest route and a termite and WDO operation are underwritten differently.
The federal backdrop is FIFRA, under which the states run applicator certification, with EPA occupational pesticide safety guidance and OSHA respiratory protection requirements governing how the work is performed. If you want a Texas program built to clear the filing rather than merely to price well, tell us how your operation runs.