Editor’s note: You can Take Action Regarding the Looming ACTS Deadline in our Advocacy Center.
By Michael Bilfinger, Assistant Director of Public Policy, AACRAO
The White House issued a Presidential Memorandum on August 7, 2025, that called for greater transparency in college admissions. On August 15, the U.S. Department of Education (Department) announced a new, extensive data collection—the Admissions and Consumer Transparency Supplement (ACTS) survey—that would be added to the existing Integrated Postsecondary Education Data System (IPEDS), the federal data-collection system used by colleges and universities to report institutional characteristics. The new ACTS component is meant to ensure race-based preferences are not used in university admissions processes.
ACTS requires certain four-year institutions with selective admissions to submit disaggregated data on applications, admissions, enrollment, and aid that’s broken down by race-sex pairings, GPA quintiles, test-score quintiles, family income ranges, Pell-grant eligibility, parental education (first-generation status), application round (e.g. early action/decision vs. regular), and more. For graduate/professional programs, data would be reported by field of study (CIP code). Much of this information has never previously been asked for as part of IPEDS reporting and ACTS requires schools to submit this information for seven total academic years (2019-20 through 2025-26). ACTS data collection opened on December 18, 2025, and will close on March 18, 2026.
The Department has made clear this new reporting is not optional. Institutions that do not comply with the requirement to complete and submit their IPEDS surveys, which includes the ACTS component, could risk a fine or other administrative action, such as a limitation, suspension, or termination of eligibility to participate in the Title IV, HEA programs.
AACRAO has major concerns about the ACTS and we have joined several community letters as well as submitted our own comments raising these to the Department. For example, IPEDS currently does not collect admissions and financial-aid information at the level of detail required under ACTS. This additional reporting is coming in the wake of the Department cancelling the IPEDS training contract that served to train and support IPEDS data reporters on campuses. AACRAO is also concerned that institutions simply won’t have some of the data being requested, particularly because the Department is requiring seven years of data. However, some state-level retention periods are as short as one-year. This means that if institutions are following their own state regulations and destroying records, then they will not have seven years of data. When state-level records requirements do not exist, institutions implement their own records retention policies. In such cases, AACRAO recommends that 4-year institutions retain student records for one year after the application term and “until the administrative need is satisfied” for community and technical colleges.
Another major concern of ours is the substantial administrative burden this reporting will inflict on institutions. The Department’s own estimates of the average time for this year’s ACTS data collection (200 hours) is more than double the estimated time for all other IPEDS survey components combined (78.5 hours). Furthermore, the Association for Institutional Research (AIR) released a survey to better understand the experiences of colleges and universities as they work to submit data for the ACTS. The survey received 390 responses from a variety of institutions including public, private non-profit, and private for-profit schools. Approximately 90 percent of respondents identified one of four primary barriers affecting timely and accurate submission: (1) staffing capacity; (2) data availability or quality; (3) interpretation of definitions or requirements; and (4) timing or uncertainty related to evolving guidance. For example, only 1% of respondents said staffing capacity and workload constraints weren’t a challenge to submitting their data and 71% of respondents believe data availability across systems will pose a moderate to major challenge to submitting their data.
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