Licensing & Regulations

Tennessee's Legislative Session Ends This Week. Three Bills Will Reshape Private Security Before the Gavel Drops.

By Daniel Whitfield · · 8 min read

Seventy-one to twenty-five.

That was the House vote yesterday on the bill that will, once the governor signs it, require every sheriff in Tennessee to sign a 287(g) agreement with Immigration and Customs Enforcement. The Senate is expected to take up the same measure this week. If it clears that chamber, it goes to Bill Lee’s desk. The 114th General Assembly is scheduled to adjourn sine die on Thursday, and the math in both chambers suggests the bill moves before the gavel falls.

If you run a contract security company in Tennessee, the legislators finishing their work this week are rewriting pieces of the environment you operate in. They didn’t mention your industry by name. They almost never do. The bills that reshape private security in this state usually pass under other headlines, and this session is running true to form.

Here is what is changing and why it matters to anyone with a TDCI license on the wall.

The Sheriff-ICE Mandate and Your Client Roster

The bill is SB2223 in the Senate, HB2219 in the House. Sen. Jack Johnson of Franklin carried it on one side of the Capitol, Rep. Johnny Garrett of Goodlettsville on the other. The text requires every sheriff in Tennessee to enter into an agreement with ICE under Section 287(g) of the Immigration and Nationality Act. Counties that refuse risk losing state funding. Campus law enforcement and local police departments are pulled in alongside the sheriffs.

ICE offers four types of 287(g) agreements. The narrowest is the jail enforcement model, where sheriffs check the immigration status of people already booked into their facilities. The broadest is the task force model, where deputies and officers can make immigration arrests out in the community, not just in the jail.

The Tennessee Senate chose language that doesn’t specify which model. That decision will get made county by county. A sheriff in Williamson County will probably sign a limited jail-enforcement agreement and call it done. A sheriff in a rural East Tennessee county might sign the task force version and start running operations at apartment complexes and job sites on Saturday mornings.

For contract security companies, the practical question is where your posts are. If you staff guards at an apartment complex in Rutherford County, a logistics yard in Hamilton County, or a construction site in Bradley County, your team is going to be in the same physical space as deputies operating under new federal authority. That changes the coordination calls your supervisors need to make. It changes how your dispatchers handle a gate call from a property manager who just watched three ICE vehicles roll up to the clubhouse at 6 a.m. and doesn’t know what to do.

Your guards don’t enforce immigration law. Nobody is asking them to. The risk is different. It is the risk of a post officer making a judgment call during a federal enforcement operation, on the property you are contracted to protect, without any written protocol to follow. Most contract security companies in Tennessee do not have that protocol. Until this week, most of them didn’t need one.

They need one now.

Campus Posts and the Charlie Kirk Act

HB 1476 passed the House two weeks ago. The Senate companion, SB 1741, cleared the other chamber the same day. Rep. Gino Bulso of Franklin sponsored the House version. Sen. Paul Rose of Covington sponsored the Senate version. The measure is named after Charlie Kirk, the conservative activist assassinated in September, and it requires public colleges and universities in Tennessee to adopt the University of Chicago’s free speech policy.

The practical piece is the discipline language. Students and faculty who disrupt a campus speaker through protest or walkout become subject to suspension or expulsion. The bill doesn’t spell out which officials make that determination in the moment, and that is where private security gets pulled in.

Public universities in Tennessee contract extensively with private security firms. Event coverage, after-hours perimeter patrol, parking enforcement, secondary gate control. Look at any football Saturday at the University of Tennessee or a commencement ceremony at the University of Memphis and you will find licensed contract guards working alongside campus police and off-duty city officers. When a speaker event turns into a walkout, the first people asked to document what happened are often the contract guards nearest the exit.

Documentation in that scenario is now the front end of a disciplinary pipeline that can end with a student being expelled. That is a different weight than writing up a trespass incident. Your guards need training on it. Your incident report templates need a section for it. Your insurance carrier needs to know about it.

The bill has some provisions that take effect immediately upon signature and others on July 1. The administrations at public colleges have been told the policy is coming. The security contractors who serve those schools have, in almost every case I am aware of, not been looped in.

The Undercover Officer Privacy Shield

The third piece of this session’s public-safety package is HB 2506, the law enforcement privacy bill. It passed in March. We covered it briefly in the April 3 post. With the session in its final days, a few details deserve a second look.

The bill shields personal information for officers working in undercover and high-risk assignments, specifically naming immigration enforcement operations as a covered category. State and local government entities have to keep that information confidential. Records requests that would have returned an officer’s name or badge number in a specific operation no longer do.

Private security companies regularly coordinate with local law enforcement on shared sites. A mall in Cool Springs, a downtown residential tower in Nashville, a hospital campus in Chattanooga. If your company has standing relationships with the Franklin Police Department or the Metro Nashville PD, the liaison officer you work with may be the same person one week and a stranger the next. Their operational identity is now protected by statute.

The practical effect is that your supervisors need new language in their shift briefings. Something like: if an officer on scene identifies themselves as working a privacy-protected operation, your team does not document names, does not photograph vehicles, and does not transmit identifying details over unencrypted radio. Your written post orders need that language. Most don’t have it yet.

What the Session Didn’t Do

A couple of bills that would have touched private security more directly went nowhere this year. HB 89 and SB 349, which would have tightened the exemption structure around off-duty peace officers working private security side gigs, stalled in committee. That means the current exemption framework under T.C.A. 62-35-101 carries through for another year. An off-duty deputy working a wedding reception in Murfreesboro on Saturday night continues to operate under the same gray-area rules he was operating under in January.

A proposal to create a separate TDCI registration category for cybersecurity services never got a floor vote. That gap between physical security licensing and cybersecurity work stays exactly where it has been, which is to say wide open. Companies that offer both sides under one corporate umbrella continue to exist in a regulatory space where one half of their revenue is regulated and the other half is not.

The consolidation of TDCI enforcement authority also stayed quiet this session. After the Solaren matter in Nashville last year, there was some expectation that the legislature would revisit badge, uniform, and insignia rules for contract security companies. It did not happen. The rules you were operating under in 2025 are the rules you are still operating under today.

The Math for TN Security Operators

Seven thousand two hundred and forty-four bills were introduced in this General Assembly across the 2025 and 2026 sessions combined. Several hundred are passing. Three of them matter directly to the way your company operates in the field. Two more matter to the way your people interact with law enforcement.

Nobody is going to send you a summary. The Tennessee Association of Security Companies will probably publish something in its next newsletter. TDCI will issue a bulletin when the attorney general’s office gets around to the implementing guidance. Neither of those is going to arrive in time to cover a shift briefing on Monday morning.

The operators I trust in this state already have someone tracking the General Assembly through the legislature’s own bill tracker at wapp.capitol.tn.gov or through legiscan.com/TN. That person reads the text, not the summaries. They flag anything that touches T.C.A. Title 62 Chapter 35, Title 38, Title 39, and Title 40. The companies that don’t have that person end up with the news the same way their property managers get it: from the evening news, several weeks late, usually from a reporter who got the bill number wrong.

A session that is about to end on the same week as a sheriff-ICE mandate passing is not a slow news cycle for private security. It is a notice. The ground is moving. How much your company moves with it is a decision you make between now and July, when most of these provisions take effect.

The General Assembly reconvenes in January 2027. What it does next depends in part on what the industry tells its representatives between now and then. Which, historically, has been very little.

Worth changing that.