Our guide to verification highlights what you’ll need for the 2026-2027 award year.
By Siobahn Arbogast
The Department of Education has posted the Federal Register and accompanying Dear Colleague Letter for verification for the 2026-2027 award year. For access to these postings, you can find the Federal Register here and the Dear Colleague Letter here.
As a friendly reminder, the Statement of Educational Purpose can no longer be required by institutions. Also, two new means of identification are now acceptable:
1) A video call between the student and institutional personnel as a substitute for the notary statement when the student cannot appear in person at the school
2) Documentation that the student had their identity verified by a third party using a method satisfying the National Institute of Standards and Technology Identity Assurance Level 2 (NIST IAL2) standard
AN OUTLINE OF ITEMS TO BE VERIFIED FOR THE 2026-2027 AWARD YEAR FOR EACH VERIFICATION GROUP
V1
Tax Filers and Non-Tax Filers:
▪ Family Size
Tax Filers:
▪ Adjusted Gross Income
▪ Income Earned from Work
▪ U.S. Income Tax Paid
▪ Untaxed Portions of IRA Distributions
▪ Untaxed Portions of Pensions
▪ IRA Deductions and Payments
▪ Tax Exempt Interest Income
▪ Education Tax Credits
▪ Foreign Income Exempt from Federal Taxation
Non-Tax Filers:
▪ Income Earned from Work
V4
Identity
V5
Tax Filers and Non-Tax Filers:
▪ Family Size
▪ Identity
Tax Filers:
▪ Adjusted Gross Income
▪ Income Earned from Work
▪ U.S. Income Tax Paid
▪ Untaxed Portions of IRA Distributions
▪ Untaxed Portions of Pensions
▪ IRA Deductions and Payments
▪ Tax Exempt Interest Income
▪ Education Tax Credits
▪ Foreign Income Exempt from Federal Taxation
Non-Tax Filers:
▪ Income Earned from Work
Please note:
U.S. tax filers: All items (with the exception of Foreign Income Exempt from Federal Taxation) will not need to be verified if the tax data is transferred directly from the IRS (FADDX). For tax filers whose information was not transferred directly from the IRS, and for Foreign Income Exempt from Federal Taxation, the filer must provide one of the following:
- A transcript obtained at no cost from the IRS or other relevant tax authority of a U.S. territory or commonwealth or foreign government; or
- A copy of the income tax return and the applicable schedules that were filed with the IRS or other relevant tax authority.
Family Size: If family size is transferred directly from the IRS and is not changed, it will not need to be verified. If it is not transferred directly from the IRS or is updated on the FAFSA, you must collect a signed statement that lists the name and age of each family member for the 2026-2027 award year and the relationship of that family member to the applicant. However, if the manually reported family size is the same as the information transferred from the IRS (FADDX), you are not required to verify the family size.
Rollovers: If the Untaxed Portions of IRA Distributions or Untaxed Portions of Pensions contain a rollover, you must collect a signed and dated statement confirming the amount of the rollover. This is required whether or not the information is transferred directly from the IRS.
Non-Tax Filers: You must collect:
▪ A signed and dated statement certifying –
- The individual is not required to file a 2024 income tax return; and
- The sources and amounts of earnings, other income and resources that supported that individual for the 2024 tax year
▪ For individuals without an SSN, ITIN or EIN, the statement must indicate that these numbers haven’t been issued
▪ A copy of the IRS Form W-2 for each source of 2024 employment income received or an equivalent document; and
▪ Except for dependent students, verification of non-filing for individuals who would file a return with a relevant tax authority other than the IRS dated on or after October 1, 2025.
If a non-filer cannot obtain the required verification of non-filing status from the relevant tax authority and the school has no reason to question the student’s or family’s good-faith effort to obtain the required documentation, the school may accept a signed statement certifying that the individual attempted to obtain the verification of non-filing from the relevant tax authority and was unable to obtain the required documentation.
SPECIAL CIRCUMSTANCES
Joint Returns: Tax filers who filed a 2024 joint income tax return at the time of the FAFSA and are now separated, divorced, widowed or married to someone other than the spouse on the 2024 joint income tax return, you must collect:
- A transcript obtained from the IRS or other relevant tax authority that lists 2024 tax account information; or
- A copy of the income tax return and applicable schedules that were filed with the IRS or other relevant tax authority; and
- A copy of the W-2 for each source of 2024 employment income received or an equivalent document.
Filing Extensions: For an individual who is required to file a 2024 IRS income tax return and has been granted a filing extension by the IRS beyond the automatic six-month extension, you must collect:
- A signed statement listing the sources of any 2024 income and the amount of income from each source;
- A copy of the IRS’s approval of an extension beyond the automatic six-month extension;
- A copy of IRS Form W-2 for each source of 2024 employment income received or an equivalent document; and
- If self-employed, the signed statement must indicate the amount of estimated Adjusted Gross Income and U.S. income tax paid for the tax year 2024.
Please note: An individual called up for active duty or qualifying National Guard duty during a war or other military operation or national emergency is permitted to submit a statement certifying he or she has not filed an income tax return or a request for a filing extension because of that service.
Tax Related Identity Theft: For individuals who are the victim of IRS tax-related identity theft, you must collect:
- A copy of the signed 2024 income tax return and applicable schedules filed with the IRS; and
- An IRS 4674C Letter (letter from the IRS acknowledging the identity theft) OR a statement signed and dated by the tax filer indicating that he or she was the victim of IRS tax-related identity theft and that the IRS has been made aware of the tax-related identity theft.
Amended Returns: For an individual who filed an amended IRS return, you must collect a signed copy of the 1040X that was filed with the IRS. The 1040X must include the changes made to the tax filer’s 2024 tax information, as well as one of the following:
- Income and tax information from the IRS on an IRIS record with all tax information from the original return;
- A transcript obtained from the IRS that lists 2024 tax account information of the tax filer(s); or
- A signed copy of the 2024 IRS Form 1040 and the applicable schedules that were filed with the IRS.
In some cases, the IRS may have made changes to amend the tax return information. For these cases, a 1040X will not exist. Instead, the filer should provide a copy of the IRS letter outlining the changes that were made. They must still provide one of the items listed in the three bullets above.
Incarcerated/Confined Students: For students who are confined or incarcerated, verification of identity is all that is needed. This will only apply to those selected for verification groups V4 and V5. These applicants will not need to verify any other items. Nothing will be required for applicants selected for verification group V1.
The Department of Education will consider a confined or incarcerated individual’s identity to be verified if their identity was verified by an authorized official at the correctional facility where the individual is confined or incarcerated.
Applicants Eligible Only for Unsubsidized Aid: Under certain circumstances, an applicant may be excluded from verification. 668.54(b) provides the list of exclusions. One exclusion pertains to applicants who are only eligible for unsubsidized aid. Per this regulation, verification would not be required for these applicants. However, the department has indicated that the school should verify identity for applicants only eligible for unsubsidized aid who are selected for group V4 or V5. You would not need to verify any of the other items included in verification for group V5 for these applicants.
Although verification is not required for these applicants, the department believes verification of identity will help ensure that only eligible students are receiving federal student aid. For information on this issue, please see the regulation cited above as well as the verification section of the Program Integrity Information Page Q&A – VER-Q6/A6 and DOC-Q18/A18. This is a direct link to the Q&A for verification.
Although this is not required from a regulatory standpoint, Global believes verifying this item for these students is a good practice.
Siobahn Arbogast is Global’s Director of Title IV Accounting.
December 11, 2025