February 19, 2026
What Higher Education Leaders Need to Know About the New ACTS Requirements
The ACTS collection window opened December 18, 2025. The deadline is March 18, 2026. That’s a 90-day window to compile, reconcile, and submit up to six years of disaggregated admissions, financial aid and outcomes data for roughly 1,660 four-year institutions nationwide.
by Laurie Capozza, Dynamic Campus Vice President, Shared & Professional Services
ACTS Is Live. Here’s What Year 1 Actually Looks Like.
In our January post, we made the case that ACTS is more than just a compliance exercise but rather a leadership opportunity. That’s still true. But with the deadline now firmly in view, the conversation has shifted from strategy to execution. And for many institutions, that’s where the real challenge begins.
Year one of ACTS isn’t just about gathering data you already have. For most institutions, it will surface data you don’t have — or data that exists somewhere across campus but has never been integrated, validated, or formatted for federal reporting.
Our institutional research team broke down the ACTS requirement and what it means for your institution in a short video.
The Data Gap Problem Is More Common Than You’d Think
Consider the data that ACTS actually requires:
In a survey of institutional research professionals conducted by the Association for Institutional Research, 70% of respondents said parental education data is either unavailable or would require significant effort to retrieve. For family income ranges, that figure climbed to 76%.
Those numbers aren’t outliers. They’re the norm. And they reflect something ACTS has now made impossible to ignore: the data infrastructure at most institutions was never designed for this level of integration or transparency.
Siloed Systems Create Outsized Compliance Risk
The deeper problem is structural. Admissions data lives in one system. Financial aid lives in another. Academic records and outcomes data in yet another. For decades, those silos were inconvenient but manageable. ACTS makes them a liability.
The NCES Aggregator Tool requires institutions to upload student-level data files that cross all of those systems, including: applicants, admitted students, enrollees, aid recipients, and graduates. The data must be matched, validated, and ready for federal submission. The compressed timeline compounds complexity to change old or create new systems.
The data must be matched, validated, and ready for federal submission. Institutions that haven’t built cross-functional data pipelines are now facing a compressed timeline to do exactly that.
This is where project management becomes critical. Bridging historically siloed offices–such as admissions, financial aid, the registrar, and institutional research— requires coordination that doesn’t happen on its own. Someone has to own it. And in year one, that work has to happen fast.
The Stakes Are Real
ACTS is an IPEDS survey component, which means participation is mandatory for institutions that receive federal Title IV funding. Failure to submit complete surveys on time carries a penalty of up to $71,545 per violation under Title IV HEA regulations (34 CFR 668.84, 668.85, and 668.86).
That’s a meaningful risk for any institution still working through the mechanics of first-year submission, particularly given the compressed timeline, the retroactive data requirements spanning six academic years, and the reduced federal capacity to provide technical support. All six NCES staff members who previously worked on IPEDS data collection were laid off earlier this year, and the IPEDS training contract was canceled.
Institutions are being asked to do more, faster, with less help from the agency that created the requirement. That’s not an argument against compliance. It’s an argument for getting the right support in place now.
Building for Year 2 — and Beyond
The institutions that will navigate ACTS most successfully in year one are those treating it as an opportunity to build something durable: repeatable workflows, auditable data pipelines, and cross-functional governance that makes future cycles faster and less painful.
That’s a different kind of challenge than most compliance exercises. It’s not just about hitting a deadline. It’s about establishing the data practices that will define how your institution reports, communicates, and leads for years to come. ACTS will inevitably reveal data gaps that need to be addressed head-on — and the institutions that address them thoughtfully in year one will carry a meaningful advantage into year two and beyond.
With Institutional Research as a Service from Dynamic Campus, your institution gains a partner who stays ahead of evolving compliance requirements while giving your team the freedom to focus on mission critical strategy.
If your team is navigating the year-one lift and you’re looking for accurate reporting, trusted expertise, and a partner who truly understands higher education, Dynamic Campus is here to help. Just click the button below to arrange a free consultation.
Dynamic Campus has served as a strategic partner for higher education institutions since 2002, enabling and accelerating success by helping transform technology processes and platforms.
