Comal County's median sale price was $439,018 over the three months ending September 2026, per Redfin. Hays County came in at $399,900 for September, per the Unlock MLS Central Texas Housing Report released October 13. If your 2026 appraisal from CAD landed above those numbers and you own a fairly standard home, you probably have a protest sitting on the table that you haven't filed.

Most people don't file. Then they complain in October when the tax bill lands.

I've sat through enough informal hearings at both Comal and Hays CADs to tell you the ones that win and the ones that get waved off in four minutes. The difference isn't passion. It's paperwork.

The math everyone misses

Here's the stat that should change how you think about this year specifically. In Hays County, closed home sales fell 30.5% year over year in September 2026 while the median sales price rose 10.8%. Fewer transactions, higher prices on the ones that closed. That's a selective market — buyers paying up for the specific houses they want and ignoring the rest.

What that means for your protest: the comps the appraisal district pulled are probably skewed toward the stuff that actually sold, which is the nicer, updated, better-located inventory. If your house isn't in that bucket, you've got an argument. The CAD mass-appraisal model doesn't know your HVAC is 14 years old. It doesn't know the slab has a crack in the garage. It doesn't know your lot drops off into a drainage easement on the back third.

You have to tell them.

What actually works at the hearing

Three things move the number. In this order.

One — equity comps. Not sales comps. Equity. You pull five to ten neighboring properties that are physically similar to yours and show that their appraised value per square foot is lower than yours. Texas law gives you the right to be appraised equally with similar properties, and the equity argument wins more informal hearings than the market-value argument does. The CAD appraiser can't easily rebut it because it's their own data.

Two — condition evidence. Photos of everything that's wrong. Roof age with a receipt or lack of one. Foundation issues with a written estimate from a structural engineer or foundation company. Old windows, old HVAC, septic that's at the end of its design life. A contractor bid for repairs is worth more than ten pages of your own description. If you've got a $14,000 foundation bid in hand, that comes off the market value, usually dollar for dollar at the informal.

Three — bad sales comps. If the CAD's evidence packet shows your house compared to three sales that closed six months before yours and all have pools and you don't, call that out specifically. Line by line.

What doesn't work: telling the appraiser your taxes went up too much. They don't set the rate. They set the value. The rate is a school board and commissioner's court problem, not theirs. Save that speech for a different meeting.

Where Comal and Hays differ

Comal CAD is in New Braunfels. Hays CAD is in San Marcos. Both run informal hearings before the formal ARB (Appraisal Review Board) hearing, and 80% of protests settle at the informal if you show up with evidence. Don't skip the informal thinking you'll do better at the formal — the ARB tends to anchor to whatever happened at the informal.

Hays County has a wrinkle worth knowing. The Hays Trinity Groundwater Conservation District is in an Emergency Drought Stage and isn't accepting new permits for non-exempt well construction. Water wells in parts of the county are failing at a pace nobody's seen before. If you're on a well in the western or southwestern parts of the county and your pump has had to be lowered, that's a legitimate condition issue affecting value. Get the well service invoice, bring it to the hearing.

Comal has its own version. The Texas Water Company recently terminated nine water utility agreements, halting over 4,000 planned homes. If your property's long-term water situation got worse this year — a utility agreement collapsed, your rural water provider announced moratoriums, anything documentable — that's evidence. The CAD doesn't track that automatically. You have to bring it.

Septic matters too. Hays County requires permits on all properties with no 10-acre exemption, and anything over the Edwards Aquifer recharge zone needs an aerobic system with a mandatory two-year maintenance contract. Comal still has the 10-acre exemption for a single-family dwelling. If you've got an aging conventional septic in Hays that's going to need to be replaced with aerobic at $12,000-$18,000, that's a real deduction from market value if you can document it.

The deadline and the play

Protest deadline is May 15 or 30 days after your notice is mailed, whichever is later. If you're reading this in October, you're reading it for next spring. Set a calendar reminder for April 15 to pull your notice as soon as it hits.

Between now and then, do three things. Walk your property with a camera and document everything that's dated, broken, or deferred. Pull five neighboring properties on the CAD website and write down their appraised values per square foot — you're looking for ones lower than yours. And if you've got any work orders, repair estimates, or inspection reports from the last two years, put them in a folder.

For investors: this matters more than people think. On a rental doing $2,400 a month, a $75,000 reduction in appraised value in Comal at roughly 2% total tax rate is $1,500 a year back in your pocket. That's not a rounding error, that's 5% of your gross rents.

You can file the protest yourself, you can use a service that takes 30-40% of the first-year savings, or you can hire a property tax consultant for a flat fee. The service model works fine on a $400k house. On anything over $700k or any commercial property, hire the flat-fee consultant and keep the upside.

Nobody at the CAD is going to lower your value because they feel bad. They'll lower it because you handed them a reason they can defend in a file.

Data sourced from Redfin's 2026 Comal County housing market report and the Unlock MLS September 2026 Central Texas Housing Report via openPR.com. Verify current numbers with a local agent before acting.