Editor’s Note: This year’s National #TransferStudentWeek runs October 19-23, 2026. Learn how you can support “Start from Yes,” the Joint Statement on Credit Evaluation & Learning Mobility. During this week, CollegeSource also hosts its 9th Annual Transfer Week Webinar Series, which is free and open to all interested.
By Michael Bilfinger, Assistant Director of Public Policy, AACRAO
The Trump administration has long sought to overhaul the college accreditation system, and on April 23, 2025, the President issued an Executive Order, “Reforming Accreditation to Strengthen Higher Education,” that directed the Secretary of Education to take several steps toward realizing this goal. The Department of Education then convened the Accreditation, Innovation, and Modernization negotiated rulemaking committee, which met in April and May before reaching consensus on May 21, 2026. The resulting Notice of Proposed Rulemaking was published in the Federal Register on August 20, 2026, and proposes the agreed-upon consensus language, proposing comprehensive revisions to 34 CFR Parts 600, 602, and 668.
Overview
The Accreditation, Innovation, and Modernization Notice of Proposed Rulemaking is the single biggest overhaul of the college accreditation system this century. The proposed rule makes it easier for new accreditors to gain federal recognition and for institutions to change accreditors, increase the transparency of transfer of credit policies, and adds requirements on academic freedom and intellectual diversity. Other major pieces include:
- Competition among accreditors. The rule would eliminate the two-year rule, which previously required new accrediting agencies to operate for at least two years before applying for federal recognition, and state that recognition confers no antitrust immunity. Institutions switching or adding accreditors would face fewer hurdles, though the Secretary could still reject a change aimed at evading federal requirements or enforcement.
- Viewpoint neutrality. Accreditor decisions would have to be neutral on viewpoint and ideology, except for agencies with a religious mission.
- Student outcomes. New program-level performance expectations would focus accreditors on measures such as completion, licensure pass rates, and economic returns.
- Teach-outs. Requirements for teach-out planning, including transcript access, would expand.
Transfer of Credit: A Closer Look
AACRAO was heavily involved through the negotiated rulemaking process by communicating with negotiators around the table and sharing resources, such as the LEARN Commission report, to help inform their discussion. AACRAO was particularly involved when it came to changes related to the transfer of credit. These changes are among the most consequential for institutions and the Department’s rationale will likely come as no surprise: students lose an average of 43 percent of their credits during the transfer process and overhauling the regulations governing this process could combat that.
The transfer provisions work mainly through two channels: accreditor recognition criteria and institutional disclosure rules. ED proposes amending § 602.24(e) to require additional criteria in institutions’ transfer policies, adding criteria to § 668.43(a)(11), and amending § 668.43(c)(3) with new disclosure requirements. In practice, accreditors would have to verify that their institutions meet these expectations.
Accreditor Recognition Criteria:
Accreditors would need to confirm that institutions award undergraduate transfer credit for successfully completed coursework from institutions accredited by a federally recognized agency when the coursework is comparable in content and learning outcomes, unless a written justification for the credit denial is provided to the learner. More on the written justification and related institutional disclosures in a moment, but for now the important thing to know is that “nothing in these proposed regulations … requires an institution to disregard its own academic standards or curricular requirements.”
The standard for determining whether a transfer credit must be accepted is comparability of content and outcomes, not the source institution’s accreditor or institution type. Practically speaking, this means institutions cannot deny credit based on the accreditor of the source institution or the type of source institution (ei: community college, for-profit) so long as the accreditor is federally recognized. That language targets longstanding practices in which credits from certain accreditors or sectors were treated as second-class.
Institutional Disclosures:
To be clear, institutions can still deny transfer credit, they just cannot do so based on the accreditor of the source institution or the type of source institution. Institutions may deny credit that fails to meet their standards, however they now must give written reasoning for the denial, and they must be sure to do so prior to asking the learner to make a nonrefundable financial commitment. That rationale must be course-specific, and students must be given an opportunity to appeal within 15 calendar days. The proposed rule also amends § 668.43 to require transfer-of-credit disclosures and direct written notice to students. ED’s stated aim is to give students a fuller understanding of the scope and cost of their education before they enroll.
Institutions are advised to review their transfer policies, since these new restrictions on denying credit based solely on accreditor identity, plus the written-justification and appeal requirements, may require revisions to current policies and procedures. Registrars and enrollment leaders should also expect to build workflows for course-level rationales, appeal intake, and the 15-day appeal window.
Timeline and Status
Comments were due September 21, 2026, and the Department received over 2,800 submissions, including the comments from AACRAO. ED remains committed to publishing the final regulations by November 1, 2026, so that the effective date will be July 1, 2027. It’s important to remember that these regulations will be enforced via accreditors, not ED, so although the effective date is July 1, 2027, that does not mean enforcement will necessarily start for your institution at that time. It will likely depend on where your institution is in its own accreditation cycle, but schools should still plan to have policies in place come July 1, 2027.
National Transfer Student Week
October 19-23, 2026 is the 9th Annual National Transfer Student Week, a free week of engaging conversations, timely research, and practical strategies celebrating the power and potential of student transfer in higher education. Lots of organizations and institutions have ways to celebrate transfer students, including:
- “Start from Yes,” the Joint Statement on Credit Evaluation & Learning Mobility, developed through the work of the Learning Evaluation and Recognition for the Next Generation (LEARN) Commission.
- CollegeSource hosts its 9th Annual Transfer Week Webinar Series, which is free and open to all interested.
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