Dear AACRAO Community,
I want to provide you with an update regarding institutional reporting requirements under the Admissions and Consumer Transparency Supplement framework and AACRAO’s recent advocacy efforts.
As a brief background, on August 15, 2025, the U.S. Department of Education (ED) announced a new, extensive data collection—the Admissions and Consumer Transparency Supplement (ACTS)—that would be added to the existing IPEDS reporting. ACTS is the largest expansion of IPEDS reporting in history, adding thousands of new data fields. Institutions are facing significant technical and environmental challenges that hinder their ability to submit accurate and complete data by the original March 18, 2026, deadline. Consider sending a letter to your Congressional representatives raising awareness of ACTS, urging them to support extending the reporting deadline to June 18, 2026, using AACRAO’s Advocacy Center.
While not the comprehensive result we are seeking, our advocacy has already resulted in the opportunity for institutional keyholders (by individual institution request only) to ask for an ACTS reporting extension until April 8, 2026, if they have completed all screening questions for all seven ACTS years and have uploaded at least three years of data to the IPEDS data collection system. This request can be made to the IPEDS Help Desk.
Last week, a group of seventeen state attorneys general sued the U.S. Department of Education to prevent the ACTS component from being implemented. The judge assigned to the case issued a temporary restraining order extending the deadline to complete the ACTS survey from March 18 to March 25, 2026. Shortly afterwards, the National Center for Education Statistics updated the ACTS deadline on the IPEDS website to March 25, 2026, as well. The legal claims raised in this case underscore the importance of ensuring that federal data systems are implemented in accordance with established law and best practices.
AACRAO, alongside several higher education associations, has joined an amicus brief submitted to the court in support of this lawsuit challenging ACTS. An amicus brief is a legal document filed by individuals or organizations who are not parties to a case but have a strong interest or expertise in the subject matter. It is an opportunity for us to tell your story. This decision to file a brief reflects the longstanding commitment of AACRAO to ensuring that federal data systems are developed thoughtfully, transparently, and in ways that serve learners, institutions, and the broader public good.
We recognize that you have been preparing for these reporting requirements and encourage institutions to continue that effort. This remains in active litigation, so institutions that cannot meet the published March 25 deadline should consult with their counsel as they work to be compliant with the law.
We will continue our advocacy efforts for higher education and will keep you informed as we know more.
Sincerely,
Melanie Gottlieb,
Executive Director, AACRAO
Addendum added 3/25/2026
On March 24, 2026, the judge assigned to this case issued another temporary restraining order further extending the reporting deadline for certain public institutions. On March 26, 2026 the National Center for Education Statistics updated the ACTS deadline on the IPEDS website to March 31, 2026.
Addendum updated on 4/6/2026
On March 31, 2026, the judge assigned to this case issued an additional temporary restraining order further extending the reporting deadline only for members of the American Association of Universities (AAU) and members of the Association of Independent Colleges and Universities in Massachusetts (AICUM). On April 3, 2026, the judge assigned to the case granted a preliminary injunction blocking data reporting for only public institutions in the 17 plaintiff states while the case is considered. Please see the table below for the updated ACTS reporting deadlines:
| | ACTS Reporting Deadline |
Members of: - Association of American Universities (AAU)
- Association of Independent Colleges and Universities in Massachusetts (AICUM)
- Connecticut Conference of Independent Colleges
- Maine Independent College Association
- North Carolina Independent Colleges and Universities
- Oregon Alliance of Independent Colleges and Universities
Plus Barnard College, Bryn Mawr College, Middlebury College, Sarah Lawrence College, Swarthmore College, and Vassar College | April 24, 2026 |
| Public institutions in CA, CO, CT, DE, HI, IL, MD, MA, NV, NJ, NY, OR, RI, VT, VA, WA, WI | Preliminary Injunction Issued Blocking Data Collection While Case is Litigated |
| Private institutions in CA, CO, CT*, DE, HI, IL, MD, MA, NV, NJ, NY, OR*, RI, VT, VA, WA, WI | March 31, 2026 |
| All other institutions | March 31, 2026 |
*Private institutions in Connecticut who are members of the Connecticut Conference of Independent Colleges and private institutions in Oregon who are members of the Oregon Alliance of Independent Colleges and Universities have until April 24, 2026, to report their data.