Gainful employment in 2026: what career schools must report
The FVT/GE rule stays in force through June 30, 2027. Schools that missed the October 1 report have until January 15, 2027, and the STATS rule replaces it on July 1, 2027.
Quick answer
What is the gainful employment rule in 2026?
Gainful employment (GE) is the Department of Education rule for career training programs. A GE program must pass an earnings premium test and a debt-to-earnings test, and one that fails the same test in two of three years loses Title IV eligibility. The rule and its Financial Value Transparency (FVT) reporting apply through June 30, 2027. On July 1, 2027 the STATS rule replaces them with one earnings premium test, and a failing program loses Direct Loans.
Updated October 2026. Sourced to the STATS final rule (91 FR 40136) and Federal Student Aid announcement GENERAL-26-49 (updated October 8, 2026).
The Calendar
What applies, and when
Two rules overlap until July 1, 2027. These are the dates that matter to a career school.
| Date | What happens | Source |
|---|---|---|
| Through June 30, 2027 | The FVT/GE rule stays in force. Schools that do not early implement STATS reporting must report every applicable data element. | FSA GENERAL-26-49 |
| August 31, 2026 | Changes to 34 CFR part 685 took effect, tying Direct Loan participation to the STATS and earnings accountability requirements. | 91 FR 40136 |
| October 1, 2026 | The 2026 FVT/GE report, covering the 2025-26 award year, was due. More than 1,000 institutions missed it. | FSA GENERAL-26-49 |
| January 15, 2027 | Final deadline for any unreported or under-reported FVT/GE data from the 2024, 2025, and 2026 cycles. No further extensions. Schools may also revise earlier submissions until this date. | FSA GENERAL-26-49 |
| 2027 | The Department plans to publish draft FVT/GE and STATS data for school review, then final data later in the year. | FSA GENERAL-26-49 |
| July 1, 2027 | The STATS and Earnings Accountability rule takes effect and replaces the FVT/GE rule. The first STATS report is due October 1, 2027 for the two most recent award years, unless the Secretary sets other dates. | 91 FR 40136, 34 CFR 668.406(b) |
| 2028 and later | The annual published data is based solely on the STATS collection. | FSA GENERAL-26-49 |
Schools can early implement the STATS reporting rules for the 2026 cycle only, which drops certain data elements and reduces the burden. Early implementation has no effect on whether the earnings premium applies from July 1, 2027, or on the consequences of failing it. Schools that report data for the 2024 or 2025 cycles must still submit every data element for those years. As of October 12, 2026 we found no proposed rule in the Federal Register that would move these dates.
The Requirements
Gainful employment and STATS side by side
The STATS rule implements the earnings accountability section of the July 2025 law (Public Law 119-21, section 84001). It folds gainful employment into one framework.
| FVT and GE rule (through June 30, 2027) | STATS rule (from July 1, 2027) | |
|---|---|---|
| Programs covered | GE programs, the career training programs defined in 34 CFR 668.2. These are non-degree programs at public and nonprofit schools and programs at for-profit schools that prepare students for a recognized occupation. FVT reporting covers all Title IV programs | GE programs and eligible non-GE programs, which together cover the programs that qualify for Title IV aid |
| Tests applied | Earnings premium and debt-to-earnings (D/E) rates. A program does not meet the D/E test when its discretionary rate is above 20 percent and its annual rate is above 8 percent | Earnings premium only. The D/E definitions are removed |
| The earnings benchmark | Typical graduate earnings compared with typical high school graduate earnings | Median annual earnings of working completers in the fourth tax year after completion, compared with the median for working adults aged 25 to 34 with only a high school diploma (state or national, based on enrollment mix) for undergraduate programs. A measure is issued only with at least 30 completers in the expanded cohort and earnings matched for at least 16 |
| What failure costs | Failing the same measure in two of three consecutive years ends Title IV eligibility for the program, Pell Grants included | Failing in two of any three consecutive award years makes a low-earning outcome program, which loses Direct Loans for at least two years. Pell is at risk only through the institution-level standard at 34 CFR 668.16(t) |
| Student warnings | Warn enrolled and prospective students when a program could lose eligibility; students acknowledge the warning | Same duty for programs that could lose Direct Loans, plus a notice to Pell recipients that Pell funds count against lifetime eligibility |
| Reporting | Program File and Student File to NSLDS under 34 CFR 668.408, due October 1 after each award year | Program and student-level data, now including tuition, fees, and grants and scholarships, under 34 CFR 668.406 |
| Appeals | Through the existing process, including a hearing official review of the Department's calculation | Within 30 days of the notice, and only on the completer list, the threshold version, the earnings comparison, or other bases the Secretary sets |
| Effective | July 1, 2024 (88 FR 70004). Compliance continues through June 30, 2027 | July 1, 2027 (91 FR 40136), with part 685 changes effective August 31, 2026 |
For the full STATS mechanics read the STATS and earnings accountability explainer, and for the placement test that applies to short programs see Workforce Pell requirements.
For Career Schools
What this means for career schools
The earnings premium reads federal tax data, so you cannot report your way to a pass. You can get the completer list right, report cleanly, and help students land jobs that pay.
Allied Health
STATS reporting asks for programmatic accreditation and for the list of states where a program meets licensure requirements. Keep both current for each program. Students who finish a higher credential at your school drop out of the earlier program's measure, which helps stackable ladders.
Skilled Trades
The Department reads earnings in the fourth tax year after completion, from federal data, for students who are working and not enrolled that year. Know each program's cohort size, because a program needs 30 completers in the expanded cohort to receive a measure.
Beauty and Wellness
The rule has a tip-income provision. For occupations that qualify for the tip deduction and where at least half of workers earn tips, a program is not graded as pass or fail on earnings from tax year 2025 or earlier. Check whether your occupations are on the Treasury list cited in 34 CFR 668.402(c)(3).
Business and IT
Programs are identified by OPEID, six-digit CIP code, and credential level, and the earnings premium is judged program by program. Check that your CIP assignments match what each program really teaches before the 2027 data is published.
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Defensible Records
How to keep records that hold up
Most of what you control sits in the data you send the Department and the evidence you keep behind it.
Reconcile the completer list every award year
The Department builds the list of completers from the enrollment and program data you already report, sends it to you, and gives you 60 days to correct it. An error in the list is one of the few grounds for an appeal.
File every FVT/GE data file early and clean
A submission is not complete until all errors are resolved, and error-correction is not an accepted reason for lateness. Federal Student Aid advises filing at least a week before the deadline.
Report tuition, fees, and grants and scholarships per student
STATS adds the total of federal, state, private, and other grants and scholarships each completer or withdrawn student received. Make sure your aid and billing systems agree before the first STATS report.
Keep accreditation and licensure fields accurate
Programmatic accreditation and the states where a program meets licensure requirements are part of the report. Incomplete or inaccurate submissions can raise administrative capability concerns.
Track employment outcomes on your own record
The earnings premium comes from federal data, not from what you report. Your verified placement record serves your accreditor, your state, and Workforce Pell, and it shows you which programs are pulling earnings up or down.
Calendar the 30-day appeal window
The clock starts when the notice of determination arrives. Decide in advance who reviews the notice and who holds the completer-list evidence.
Accreditors ask for placement proof on their own terms. See our guide to ACCSC employment verification requirements and the comparison of job placement tracking software.
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Get a Free Outcomes DiagnosisHow Prentus Helps
Verified outcomes, and students who get hired
Prentus is the career outcomes platform. It does not calculate your debt-to-earnings rates or your earnings premium, which come from federal loan and tax data. It gives you verified employment outcomes of your own, and it helps students reach the jobs that move earnings.
Automatic outcome collection
An automatic monthly LinkedIn scan plus dozens of third-party sources that verify employment. AI reviews the sources and surfaces the outcomes it judges legitimate, and your staff confirm them.
Surveys that run themselves
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Placement support from day one
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Run a Free Outcomes ScanCommon Questions
Gainful Employment and FVT Reporting FAQ
What is the gainful employment rule in 2026?
Gainful employment (GE) is the Department of Education rule for career training programs, set in the Financial Value Transparency and Gainful Employment final rule (88 FR 70004), effective July 1, 2024. A GE program is measured on an earnings premium and on debt-to-earnings rates. A program that fails the same measure in two of three consecutive years loses Title IV eligibility. The rule stays in force through June 30, 2027.
Does gainful employment still apply in 2026?
Yes. Federal Student Aid told schools on October 8, 2026 that institutions that do not early implement the new STATS reporting rules must keep complying with all FVT/GE reporting requirements through June 30, 2027. The STATS and Earnings Accountability rule replaces the FVT/GE rule on July 1, 2027.
What is financial value transparency reporting and when is it due?
Financial Value Transparency (FVT) reporting is the annual program and student data file that schools send to NSLDS under 34 CFR 668.408. The 2026 cycle, covering the 2025-26 award year, was due October 1, 2026. Federal Student Aid found that more than 1,000 institutions missed it, and announced one final extension. All unreported or under-reported data for the 2024, 2025, and 2026 cycles is now due by Friday, January 15, 2027, with no further extensions, and the Department says it may consider fines, sanctions, or other actions against schools that miss it.
What changes on July 1, 2027?
The STATS and Earnings Accountability final rule (91 FR 40136) takes effect. It removes the debt-to-earnings metric and applies one earnings premium test to gainful employment programs and to the other programs that qualify for Title IV aid. A program that fails in two of any three consecutive award years becomes a low-earning outcome program and loses Direct Loan eligibility. Changes to 34 CFR part 685 take effect earlier, on August 31, 2026. As of October 12, 2026 we found no proposed rule in the Federal Register that would change those dates.
Does STATS eliminate the debt-to-earnings ratio?
Yes. The final rule removes the debt-to-earnings definitions and uses the earnings premium as the accountability metric. The Department estimated that keeping debt-to-earnings would raise the share of failing programs from 5.2 percent to 5.3 percent, about 100 more programs out of the more than 200,000 that enroll Title IV students.
What happens to a program that fails?
Under the current gainful employment rule, a GE program that fails the same measure in two of three consecutive years loses Title IV eligibility. Under STATS, a program that fails the earnings premium in two of any three consecutive award years is a low-earning outcome program and loses Direct Loans for at least two years. Pell Grants are then at risk only at the institution level, through the administrative capability standard at 34 CFR 668.16(t), which requires that at least half of a school's Title IV recipients and half of its Title IV funds do not come from low-earning outcome programs.
Which programs does STATS cover?
It applies to gainful employment programs and to eligible non-GE programs, which together cover the programs that qualify for Title IV aid at every credential level and every tax status. The older split that kept most degree programs at public and nonprofit schools outside gainful employment no longer decides who is measured. Programs with fewer than 30 completers in the expanded cohort, or without earnings matched for at least 16 students, do not receive a measure.
Can a school appeal a low-earning outcome determination?
Yes, within 30 days of the notice, and only on the grounds the rule lists. Those are the list of completers, the version of the earnings threshold applied, the comparison of the program's median earnings with that threshold, and other bases the Secretary sets (34 CFR 668.603). That is why an accurate completer list matters. The Department sends the list to the school, and the school has 60 days to correct it.
Sources
Every legal claim, date, and figure on this page traces to one of these primary sources. Updated October 2026.
- STATS and Earnings Accountability final rule, 91 FR 40136, published July 1, 2026, effective July 1, 2027. Docket ID ED-2026-OPE-0100, RIN 1840-AE06
Source for the removal of the debt-to-earnings metric, the earnings premium measure and its fourth-tax-year earnings, the low-earning outcome program consequence, the 30-day appeal grounds, the administrative capability standard at 34 CFR 668.16(t), the reporting duties at 34 CFR 668.406, and the 5.2 versus 5.3 percent failure comparison.
- Financial Value Transparency and Gainful Employment final rule, 88 FR 70004, published October 10, 2023, effective July 1, 2024
Source for the current gainful employment framework, the D/E thresholds, and the loss of Title IV eligibility after two failing years out of three.
- Federal Student Aid, GENERAL-26-49, Guidance on FVT/GE Data Reporting, STATS Early Implementation, and Next Steps for Publication, updated October 8, 2026
Source for the October 1, 2026 and January 15, 2027 reporting deadlines, the STATS early implementation option, compliance through June 30, 2027, and the plan to publish FVT/GE and STATS data in 2027.
This page is general information, not legal advice. Dates can change, so check Federal Student Aid announcements before you file.
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