The Department of Education has issued a final warning to nearly 1,800 institutions that are missing critical Financial Value Transparency and Gainful Employment (FVT/GE) data from the 2024 and 2025 reporting cycles. With a final deadline of Jan. 15, 2027 the stakes are high for these institutions to comply with federal reporting requirements.
The missing data is crucial for families making informed decisions about higher education. The FVT/GE regulations, finalized in 2023, require colleges to report detailed program-level data, including what programs they offer, what students borrow, and what they pay out of pocket. This information is used to calculate debt-to-earnings ratios and earnings benchmarks for individual programs, providing essential insights into the return on investment for specific degrees.
Compliance Challenges and Institutional Struggles
The compliance landscape is uneven, with different types of institutions facing varying degrees of difficulty. Among private for-profit institutions 53.5% are missing at least one required file, compared to 34.8% of private nonprofits and 28.5% of public institutions. Foreign institutions fare the worst, with 78.9% missing files.
Institutional research and data professionals have identified several challenges contributing to the compliance gap. Many smaller institutions, including less-than-two-year institutions and community colleges, struggle with limited resources and staff capacity. The reporting process is complex and crosses multiple institutional boundaries, involving financial aid, Institutional Research, student information systems, registrar or admissions functions, IT, and sometimes legal counsel.
One member of the Association for Institutional Research (AIR)‘s Data Policy Advisory Group noted that completing the FVT/GE reporting essentially required taking one staff member off everything else they were doing for a period of time. This highlights the significant resource allocation required for compliance.
The Reporting Process and Deadlines
Institutions face two critical deadlines. The 2026 reporting cycle, covering the 2025–26 award year, is due on Oct. 1, 2026. Any unreported or under-reported data from the 2024 and 2025 cycles must be submitted by Jan. 15, 2027. The Department of Education has made it clear that no further extensions will be granted, and error correction is not an acceptable excuse.
At a minimum, schools filing as ‘transitional reporters’ must submit seven components across the two delinquent cycles. These include a Program File and Student Annual Amount records for the 2023–24 and 2024–25 award years, plus Student Total Amount records for 2022–23, 2023–24, and 2024–25. The Program File must include every program where at least 30 Title IV students completed substantially similar programs across the four most recent award years.
There is a wrinkle for the current cycle: schools can ‘early implement’ the new Student Tuition and Transparency System (STATS) and Earnings Accountability rule by skipping certain optional data elements in their 2026 submission. This option reduces the reporting burden but does not change the accountability measures that will take effect starting July 1, 2027.
Consequences of Non-Compliance
For families, the missing data translates directly into missing information about what colleges actually cost. The Department of Education intends to publish draft statistics derived from FVT/GE and STATS data in 2027, followed by final numbers later that year. Starting in 2028, annual publications will run solely on the STATS collection, providing families with program-level debt and earnings outcomes before borrowing.
Institutions that fail to meet the deadlines must submit an explanation statement to the Secretary of Education before the deadline passes. The Department of Education has warned that it will consider taking action against institutions that fail to submit, including fines, sanctions, or other measures. This warning comes amid sweeping changes to student loans and higher education rules, raising the cost of non-compliance with federal regulators.
The Department of Education will host office hours on Sept. 10, 2026 to answer reporting questions, signaling a preference for compliance over enforcement. However, the stakes are high, and institutions must act swiftly to meet the upcoming deadlines.
