ACTS Countdown: Who Must File, What to Report, and What’s at Stake?

Quick Hits

• The Admissions and Consumer Transparency Supplement (ACTS) is a new federal IPEDS requirement for four-year colleges and universities, including graduate-only institutions, to report undergraduate and graduate admissions, aid, and outcomes data.
• Covered institutions must submit six academic years of data (2019-20 through 2025-26) during the current collection window, which closes March 18, 2026, leaving a compressed timeline to assemble both the current year and the prior five years.
• With a short runway to the ACTS submission deadline, institutions may want to move promptly to map data sources, align definitions, and address privacy and security controls, consult NCES instructions and FAQs, and prepare for potential risk-based Title VI reviews that will draw on these submissions.

Who Must Report and When

ACTS applies to four‑year, degree‑granting public, private not‑for‑profit, and private for‑profit institutions that primarily award bachelor’s degrees or higher, including institutions that award only graduate degrees. NCES opened the collection on December 18, 2025, and it will close on March 18, 2026. Reporting covers the current 2025–26 academic year plus the five prior academic years (2019–20 through 2024–25), for a total of six years. With the collection already underway and a March 18, 2026, close, institutions face a compressed timeline to compile and submit both current‑year and retrospective data. NCES has also posted collection instructions and a frequently asked questions guide (FAQs) to support filers. Institutions may be exempt in a particular year if both: (1) they were open admission or admitted 100 percent of applicants in that year; and (2) they did not award non‑need‑based aid in that year. Following the public comment periods, NCES indicated a limited change clarifying that two‑year colleges are exempt when they admit all applicants and do not award non‑need‑based aid, while the broader framework moved forward to approval.

What ACTS Signals for Compliance and Risk

ACTS enables the U.S. Department of Education (ED) to enhance transparency and facilitate widespread Title VI compliance through detailed, disaggregated reporting of admissions, aid, and outcome data. The administration’s notices and the public comments received during the notice and comment period contemplate expansive risk‑based reviews drawing on race‑ and sex‑disaggregated applicants (people who apply), admitted students (people offered admission), and enrollees (students who actually start). The data will also be grouped  by GPAand test score quintiles, application round (early/regular), family income and Pell Grant eligibility, first‑generation status, financial aid offered and received, graduation outcomes, and other factors used in admissions decisions. For undergraduate applicants, ACTS calls for unweighted secondary‑school GPA and test scores in addition to the above. For first‑time, full‑time degree/certificate‑seeking undergraduates who enroll, reporting extends to aid received, parental college attainment, and the student’s unweighted cumulative GPA after the first academic year. Comparable categories apply to graduate applicants and enrolled students, with reporting organized at the program level (e.g., by CIP code). The breadth and granularity, coupled with a tight launch window, elevate operational, privacy, and data‑quality risks.

Next Steps for Institutions Now

Institutions subject to ACTS may want to mobilize cross‑functional teams spanning admissions, institutional research, IT/data governance, financial aid, and legal to map data sources and close readiness gaps across the full lookback period. Early scoping should prioritize definitions alignment, student‑level to aggregate reconciliation, treatment of test‑optional applicants, and standardization of GPA and quintiles across feeder schools and programs. Given the potential for small‑cell privacy risks and cybersecurity considerations, institutions may also want to review de‑identification protocols, access controls, and disclosure review processes. Privileged analyses of admissions and scholarship decision factors across the reporting years, controlling for permissible criteria, may assist in informing Title VI risk assessments.

Ogletree Deakins’ Higher Education Practice Group and Workforce Analytics and Compliance Practice Group will continue to monitor developments and will provide updates on the Higher Education and Workforce Analytics and Compliance blogs as additional information becomes available.

This article and more information on how the Trump administration’s actions impact employers can be found on Ogletree Deakins’ Administration Resource Hub.

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