Federal Court Issues Temporary Restraining Order Affecting ACTS Reporting Timeline for Certain States
AIR is monitoring a recent legal development that may affect the timeline associated with the Admissions and Consumer Transparency Supplement (ACTS) reporting requirement.
A federal judge in Massachusetts has issued a temporary restraining order (TRO) pausing enforcement of the ACTS reporting requirement while litigation filed by a coalition of states proceeds. According to reporting by Reuters, the order extends the timeline for ACTS reporting through March 26, 2026, beyond the original March 18 reporting deadline, while the court considers the case. A hearing is currently scheduled for March 24, 2026.
At this time, the extension associated with the court order applies only to institutions located in the 17 states participating as plaintiffs in the lawsuit. These states include:
- Massachusetts
- California
- Maryland
- Colorado
- Connecticut
- Delaware
- Hawaii
- Illinois
- Nevada
- New Jersey
- New York
- Oregon
- Rhode Island
- Vermont
- Virginia
- Washington
- Wisconsin
For institutions located in the remaining 33 states, the original March 18 ACTS reporting deadline currently remains in effect unless additional federal guidance is issued.
Because the order is temporary and tied to ongoing litigation, it is not yet clear how this development may affect the ACTS data collection process or whether additional federal guidance will be issued to institutions.
AIR will continue monitoring official updates from the U.S. Department of Education, the National Center for Education Statistics (NCES), and the IPEDS Help Desk, and will share additional information with the community as it becomes available.
Current ACTS Extension Process
Institutions should continue to follow existing federal guidance regarding ACTS submission.
As previously communicated through IPEDS guidance, institutions that require additional time may request a conditional extension through April 8, 2026, provided that the following steps are completed by the regular March 18 keyholder deadline:
- All ACTS screening questions are completed for all seven reporting years, and
- Data for any three reporting years are uploaded to the IPEDS Data Collection System (DCS).
Institutions that meet these conditions may request an extension through the IPEDS Help Desk:
- Phone: (877) 225-2568
- Email: ipedshelp@rti.org
Institutions experiencing technical issues during submission are also encouraged to contact the Help Desk as soon as possible.
Ongoing Monitoring
AIR will continue tracking developments related to the ACTS reporting requirement and will provide updates as new information becomes available.