(GENERAL-25-46) New Reporting Portal for Reporting of Foreign Gifts and Contracts under Section 117 of the Higher Education Act of 1965 – Implementation Planned for January 2026 and Reminder of January Reporting Deadline

Author
Office of the General Counsel
Electronic Announcement ID
GENERAL-25-46
Subject
New Reporting Portal for Reporting of Foreign Gifts and Contracts under Section 117 of the Higher Education Act of 1965 – Implementation Planned for January 2026 and Reminder of January Reporting Deadline

Section 117 of the Higher Education Act of 1965, as amended (20 U.S.C. § 1011f), provides that institutions of higher education (IHEs) must file a disclosure report with the U.S. Department of Education (ED) whenever the institution is owned or controlled by a foreign source or receives a gift from or enters into a contract with a foreign source, the value of which is $250,000 or more, considered alone or in combination with all other gifts from or contracts with that foreign source within a calendar year. 

In an effort to update and improve the Section 117 reporting portal, ED will launch a new reporting portal on Jan. 2, 2026. In designing this new portal, we have attempted to incorporate many comments provided by IHEs since creation of the existing portal (June 2020). For example, the new reporting portal will facilitate “bulk uploads” for reportable gifts and contracts and will include an “executive summary” for each IHE to view the toplines of its submissions in a condensed form. In addition, the new portal will address previously articulated concerns about, among other things: (1) automatic log off; (2) duplicative and onerous submission requirements concerning identifying information for the IHE; (3) save-as-draft capability; (4) ease of review of prior draft and final submissions; (5) capacity to self-correct prior submissions (for reports submitted through the new portal); (6) ability to review and revise another institutional user’s submission; (7) summary page of entries to allow final review; (8) publication of a reporting portal user’s guide; and (9) system functionality to allow an institutional user to download the full set of records that were submitted rather than print each individual submission.

The new reporting portal for the required Section 117 disclosure reports will be located at www.ForeignFundingHigherEd.gov available on Jan. 2, 2026.

Current guidance concerning Section 117 will initially continue with no changes at this time. The current guidance and information (e.g., FAQs, deadlines) will continue to be located at Federal Student Aid’s (FSA) Knowledge Center www.fsapartners.ed.gov/knowledge-center/topics/section-117-foreign-gift-and-contract-reporting .

Training, Additional Communication Plans, and Questions

We understand that the community will have questions about the upcoming implementation of a new Section 117 reporting portal. In the coming weeks, we will provide additional information in the following ways:

  • Training Opportunities – We will provide a training webinar on Dec. 15, 2025, at 2:30 p.m. Eastern time (ET), and will publish the recording of the webinar, along with any associated materials, on Dec. 18, 2025.

  • Additional Electronic Announcements – We will publish additional Electronic Announcements that will allow IHEs to prepare for the upcoming implementation of the new reporting portal. Monitor the Knowledge Center for these announcements.

  • Questions – If you have technical questions or access issues related to the Section 117 reporting portal, you may continue to contact us at ForeignGiftsAccess@ed.gov. If those questions concern the new reporting portal, which will not be available until Jan. 2, 2026, please include “New Portal Implementation” as the subject line. Any other questions concerning Section 117 will continue to be answered by the Section 117 compliance team which can be emailed at ForeignSourceReporting@ed.gov.

The most important dates in the implementation timeline are:

Reminder

The next date by which IHEs must submit Section 117 disclosure reports is Saturday, Jan. 31, 2026. However, because this deadline does not fall on a business day, ED will treat a disclosure report submitted on the first business day following Jan. 31, 2026, as timely. Accordingly, disclosure reports must be submitted to ED no later than Monday, Feb. 2, 2026. Any failure to comply with the reporting requirement could result in an enforcement action.

We look forward to continuing to work with our IHE partners on this very important and exciting initiative.