The U.S. Department of Education has issued a reminder that institutions subject to Section 117 of the Higher Education Act (HEA) must submit any required foreign gift and contract disclosure reports by July 31, 2026. The reporting deadline is established by federal law and applies to reportable activity during the applicable reporting period.
Who Must Report?
Institutions must submit a Section 117 disclosure report if they are owned or controlled by a foreign source or if they receive gifts from, or enter into contracts with, a foreign source totaling $250,000 or more from that source during a calendar year.
Reporting Deadline
Required disclosures must be submitted through the Department of Education’s Foreign Funding Disclosure Portal by July 31, 2026. Institutions should review their foreign gift and contract activity now to determine whether a filing is required and ensure they meet the reporting deadline.
Why It Matters
The Department reminds institutions that compliance with Section 117 reporting requirements is mandatory. Institutions that fail to submit required disclosures may be subject to enforcement actions. Reviewing foreign gifts, contracts, and ownership interests before the deadline can help avoid compliance issues.
If your institution needs assistance with Title IV compliance, regulatory reporting, or federal financial aid requirements, College Aid Services provides experienced compliance consulting to help colleges and universities navigate complex federal requirements and maintain compliance.
Update on July 14, 2026
The Department has agreed to delay by two weeks—until July 29, 2026—its planned publication of the names of all “foreign sources from prior reporting cycles.” On July 15, 2026, instead of publishing “the names of all foreign sources from prior reporting cycles” in its public report, the Department will instead publish only the names of the 92 foreign entities that appear on the list entitled “Funding of Universities from Foreign Entities on US Government Lists” on the Department’s “Section 117 Foreign Gift and Contract Public Transparency Dashboard,” located at foreignfundinghighered.gov. The Department will tie specific transactions by these 92 foreign entities to specific universities.
SOURCE: (GENERAL-26-45) Reminder: Reporting Deadline for Section 117 of the Higher Education Act of 1965