(GENERAL-24-140) Update Regarding StudentAid.gov Account Creation for Individuals Without a Social Security Number

Author
Federal Student Aid
Electronic Announcement ID
GENERAL-24-140
Subject
Update Regarding StudentAid.gov Account Creation for Individuals Without a Social Security Number

In April 2024, the U.S. Department of Education (Department) announced changes to our systems that allowed applicants and contributors without a Social Security number (SSN) to immediately access the online 2024-25 FAFSA® form while still going through the manual identity validation process. As explained at that time, the FUTURE Act Direct Data Exchange (FA-DDX), which allows applicants and contributors to automatically populate their income data on the FAFSA form by pulling the data from the IRS, cannot be used by those without an SSN, but who do have an Individual Taxpayer Identification Number (ITIN), due to system development issues. The requirement in the FUTURE Act for all individuals who participate in a FAFSA form to consent to using the FA-DDX was the reason for validating the identities of all contributors to the FAFSA form and was a new requirement for the 2024-25 FAFSA form. In all years prior to 2024-25, identity validation was not required for contributors, nor was consent and approval to use the FA-DDX.

The Department extended this flexibility in July 2024 for the 2025-26 FAFSA cycle, further explaining that it will continue until the Department develops both:

  • A longer-term solution to the manual identity validation process that avoids the delays and confusion associated with the current process; and

  • The ability for those without an SSN to utilize the FA-DDX to transfer their tax information into the FAFSA form.

As a reminder, there is no adverse impact to a student’s eligibility for federal student aid. Students will receive full access to the aid they are entitled to, and contributors are not required to complete the manual identity validation process prior to aid being disbursed to a student.

Update

The Department continues to work on procuring the longer-term solution for accepting and reviewing identity documents through a secure system that does not fully rely on a manual review by Department representatives – currently planned to begin implementation in the 2026-27 FAFSA cycle. As we continue this work to improve our process, we are pausing the acceptance of new identity documents to the email inbox for manual identity review and validation. The email address IDVerification@ed.gov will be disabled. Individuals who cannot have their identity validated through the automated systems that the Department currently uses through Transunion will no longer receive a system-generated email with a case number and instructions for how to complete the identity validation process. The individual will instead receive a confirmation screen indicating that they may progress immediately to the FAFSA form and no additional steps are needed at that time. They will also receive an automated response stating that their message to IDVerification@ed.gov could not be delivered.

As a part of the Department’s efforts to improve the identity validation process, the Department has transitioned implementation of the requirement for the 2025-26 FAFSA form that those contributors without an SSN complete and submit a separate paper Attestation and Validation of Identity form certifying that they do not have an SSN. This certification has now been directly embedded into the online StudentAid.gov account creation process where the user attests to the information provided being complete and correct.

In addition, to address feedback we have received that the number of documents that could previously be submitted as proof of identity were too limited and created hardship for individuals, the Department has recently expanded the list of documents accepted as proof of identity from less than 10 options to over 30 (see list below). This should alleviate some burden on individuals when the Department has opened the new secure system for collection of documents for manual identity validation.

The Department will work to make updates to our various guidance documents and other help tools over the next few weeks to reflect this update.

What This Means for Institutions:

  • Bypassing the identity validation process does not exempt student applicants without an SSN from having to meet eligibility requirements for federal student aid. As explained in prior guidance, for students without an SSN, schools must request documentation to verify the student’s eligible noncitizen status. Additional guidance on verifying the citizen and eligible noncitizen status of students can be found in the 2024-25 FSA Handbook, Volume 1: Student Eligibility, Chapter 2. Schools must ensure that the student’s identity and citizenship status is verified before disbursing aid.

    Schools may direct students and families who have questions about their eligible noncitizen status, or concerns that their parent or spouse’s citizenship status impacts their eligibility for federal student aid, to our guidance for non-U.S. citizens.

  • Due to the attestation that an individual does not have an SSN, leading to the manual entry of income information, the Department continues to require certain actions by institutions and will take additional steps to ensure appropriate mitigation for potential fraud.

    • The Department will continue current institution-based verification practices related to identity and income verification. As those without an SSN cannot use the FA-DDX, they are more likely to be selected for income verification by their institution.

    • If an institution suspects conflicting information, such as a student or contributor who has inaccurately indicated on their FAFSA form that they do not have an SSN, the institution is required to resolve the conflicting information prior to disbursing aid.  

    • When conducting future program reviews, the Department may request to review the files for those students that either reported not having an SSN or had a contributor without an SSN to ensure that aid was disbursed to eligible students that have met all eligibility criteria, and to also verify they reported the correct income information.

    • Through these efforts, if the Department becomes aware of information regarding financial aid fraud (e.g., providing false financial information on the application), the Department may refer the case to the appropriate agencies for action.

Acceptable Identification Documents

When the Department restarts manual identification through a secure portal, individuals will have the following options of identity documents to submit. All acceptable documents submitted for verification or proof of identity must be valid (current and unexpired). The name of the individual and address on the utility bill must match the information provided on this form. Only one (1) document is required from Group A or two (2) documents from Group B.

Group A: Present one of the following valid, unexpired forms of ID:

  • Driver’s license, temporary license, or ID issued by a U.S. State or Territory (paper documents NOT accepted)

  • U.S. Passport or passport card

  • Foreign Passport or passport card

  • Consular ID Card/Matricula Consular

  • U.S. Border Crossing Card

  • U.S. Military ID Card (front and back) or U.S. Military’s dependent ID card

  • Native American Tribal ID

  • Permanent Resident Card (form I-551) “green card”

  • Government-issued Personal Identity Verification (PIV) card

  • Common Access Card (CAC)

  • Transportation Worker Identification Credential (TWIC)

  • U.S. Certificate of Naturalization (Form-550 or Form N-570)

  • DHS/ICE Miramar Check-in Paperwork – must have a photo and seal

  • U.S. Certificate of Citizenship (form N-560 or Form N-561)

  • Prison ID with picture, name, and date of birth

  • US Citizenship and Immigration Services Employment Authorization Document (EAD) (I-766)

  • US Merchant Mariner Credential

  • Veteran Health Identification Card (VHIC)

  • Documents reflecting TPS (Temporary Protected Status) eligibility

Group B: If an individual cannot provide the documents from list one, they must present two of the following. The documents must be valid and unexpired unless otherwise noted below. At least one document submitted must be a photo ID:

  • Social Security Card

  • Birth certificate or document issued by a foreign country or U.S. state, jurisdiction, or territory

  • Foreign driver’s license

  • Marriage license or divorce decree

  • U.S. Individual Taxpayer Identification Number (ITIN) provided on official letter awarding the ITIN or an official renewal ITIN letter from the U.S. Internal Revenue Service (IRS)

  • Municipal identification card (such as those issued by city ID program)

  • Community ID

  • Voter registration card

  • U.S. or foreign passport or passport card that expired within the previous 2 years

  • Consular ID from applicant’s country of citizenship that expired within the previous 2 years

  • Credit card/debit card statement

  • Mortgage statement

  • Financial institution account statement

  • Utility bill

  • Federal or State tax return

  • W-2

  • Insurance documents, including medical, dental, vision, life, home, rental, or vehicle

  • Rental or lease agreement with signature of landowner and tenant

  • Property tax bill or statement or deed or title to residential property

  • Pay stubs

  • Car registration

  • Foreign or U.S. School-issued or college ID card

  • Employee identification card

  • Union or worder center identification card

  • Foreign border crossing card (example: ECOWAS is accepted)

  • Foreign Military ID Card (front and back)

  • Foreign federal electoral photo card

  • Foreign national or federal government-issued ID cards (from individual’s home country)

  • Other foreign federal government-issued identification documents

  • U.S. Prison ID missing picture, name, or DOB can be accepted with 2nd form of ID or official document (letter or other) from prison

Contact Information

The Department welcomes our partners to continue using the Contact Customer Support form in FSA’s Partner Connect Help Center. To submit a question, please enter your name, email address, topic, and question. When submitting a question, please select the topic “FAFSA.”

Students and families with questions regarding the FAFSA form, should refer to the FAFSA Help Center.