Admissions and Consumer Transparency Supplement (ACTS) data collection—a new addition to the existing IPEDS federal data-collection system used by colleges and universities—will close on March 18, 2026. As institutions scramble to submit large volumes of information on time, this Affirmity compliance alert examines the Department of Education’s requirements and highlights a key post-submission action.
Summary
On August 7, 2025, President Trump issued a memorandum, “Ensuring Transparency in Higher Education Admissions,” requiring the Secretary of Education to “expand the scope of required reporting to provide adequate transparency into admissions, as determined by the Secretary of Education, consistent with applicable law.” The result was the Admissions and Consumer Transparency Supplement (ACTS), a new component of the IPEDS system meant to ensure race-based preferences are not used in university admissions processes.
ACTS data collection opened on December 18, 2025, and will close imminently on March 18, 2026. Institutions must submit disaggregated data on applications, admissions, enrollment, and aid broken down by factors including race-sex pairings, GPA and test-score quintiles, family income ranges, Pell-grant eligibility, and parental education. Institutions have been asked to provide seven years of academic data, covering 2019-20 through to 2025-26.
Who Is Impacted?
All four-year educational institutions with competitive admission practices must comply with the new requirements. As outlined in an American Council on Education letter to the Department of Education, the department will fine institutions that fail to submit completed ACTS surveys on time up to $71,545 per violation. The letter also noted the department’s own estimate that each institution would require 200 additional hours to complete the initial ACTS survey.
Actions Required
With institutions forced to collate seven academic years of information—a substantial amount of which has never previously figured into IPEDS reporting—with just a few months’ warning, it’s likely that many had little time to analyze the data they’re handing over.
Indeed, in their reporting, the American Association of Collegiate Registrars and Admissions Officers (AACRAO) cites an Association for Institutional Research (AIR) survey indicating that 90% of respondents have struggled with at least one of four major barriers to a timely response. These barriers include:
- Staffing capacity
- Data availability or quality
- Interpretation of definitions or requirements
- Uncertainty related to evolving guidance.
In Affirmity’s work with federal contractors of all types, we emphasize the importance of running proactive statistical analyses in order to understand what agencies may uncover.
While the imminent deadline leaves no time for analysis before submission, institutions should strongly consider conducting such analyses before further contact with the Department of Education. This will allow them to:
- Anticipate lines of questioning
- Better explain potential areas of impact
- Build a statistical basis for refuting misinterpreted datapoints.
- Build better and more efficient processes to deal with the new requirements going forward
How Affirmity Can Help?
Affirmity is interested in speaking with institutions concerned about their ACTS submission—we believe our software and consulting services can be applied to this risk assessment problem, and we encourage interested parties to reach out as soon as possible.
Understand the data you submitted—contact us today to get started.
About the Author
Charles McGhee, PhD serves as Affirmity’s lead statistician. He has over 20 years of expertise in workforce compliance in the private and public sectors. Prior to joining Affirmity, he served for 10 years as senior statistician with the Office of Federal Contract Compliance Programs (OFCCP) and Equal Employment Opportunity Commission (EEOC). Dr. McGhee holds a PhD in Biostatistics, and undergraduate and Master’s degrees in Mathematics.