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ARTICLE · 26 NOVEMBER 2025

ACTS Targets Selective Institutions: What Counsel And Admissions Need To Know

Ogletree, Deakins, Nash, Smoak & Stewart
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On November 13, 2025, the U.S. Department of Education proposed adding the "Admissions and Consumer Transparency Supplement (ACTS)" to IPEDS, narrowing applicability...

United StatesConsumer Protection

On November 13, 2025, the U.S. Department of Education  proposed adding the “Admissions and Consumer Transparency Supplement (ACTS)” to IPEDS, narrowing applicability to selective four-year institutions, introducing targeted exemptions, and updating the collection window to 2025–26 through 2026–27. Public comments are due December 15, 2025.

Quick Hits

  • The U.S. Department of Education's updated IPEDS data collection proposal clarifies that ACTS would only apply to selective four-year institutions.
  • Institutions that both admit 100 percent of applicants and award no non-need-based aid in a given collection year would be exempt from the data collection for that year.
  • The Education Department underscores the ACT's purpose to identify race-based preferencing in admissions and non-need-based aid practices, signaling potential risk-based Title VI of the Civil Rights Act of 1964 scrutiny.

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