Federal Court Extends Temporary Pause for Some ACTS Reporting Requirements
On March 24, 2026, a federal court in Massachusetts held a hearing on a request for a preliminary injunction related to the Admissions and Consumer Transparency Supplement (ACTS) data collection. The case, brought by a coalition of states, raises questions about statutory authority, implementation processes, and administrative procedure.
During the hearing, the plaintiffs’ arguments focused on whether the U.S. Department of Education exceeded its authority in implementing ACTS, whether the process aligned with requirements under the Paperwork Reduction Act, and whether aspects of the implementation could be considered arbitrary and capricious given evolving guidance and reporting expectations.
The judge indicated that portions of the case warrant further consideration and emphasized the need for additional time to fully evaluate the issues presented.
Temporary Restraining Order Extended
Following the hearing, the court extended the existing temporary restraining order (TRO) through April 6, 2026.
- The extension applies only to public institutions in the 17 plaintiff states involved in the case.
- Institutions outside those states remain subject to federal reporting requirements and updated guidance.
Additional guidance from the National Center for Education Statistics (NCES) has clarified ACTS submission deadlines:
- Public institutions in the 17 plaintiff states: Deadline extended to April 6, 2026, at midnight Pacific Time, consistent with the court order.
- All other institutions: Deadline extended to March 31, 2026, at midnight Pacific Time.
Institutions may continue to qualify for an extension to April 8, 2026. To qualify, institutions must:
- Complete all ACTS screening questions for all seven reporting years, and
- Submit data for any three reporting years to the IPEDS Data Collection System (DCS)
Both requirements must be completed by March 31, 2026, at midnight Pacific Time.
This evolving guidance introduces additional complexity for institutions navigating ACTS reporting requirements across different jurisdictions.
Institutions are encouraged to contact the IPEDS Help Desk at (877) 225-2568 or ipedshelp@rti.org with specific questions regarding submission or extension eligibility.
What This Means for Institutions
At this stage, there is no final ruling on the broader legality or future of ACTS. Additional court action is expected as the judge continues to review the case.
In the meantime, AIR encourages institutional research and effectiveness (IR/IE) offices to:
Continue preparing and validating ACTS data rather than pausing work
Monitor official guidance from the U.S. Department of Education and NCES
Consult with institutional leadership and legal counsel to determine appropriate next steps based on institutional context
AIR will continue to track developments closely and share updates as more information becomes available.