By Maria Carrasco, NASFAA Staff Reporter

The Department of Education (ED) on Wednesday unveiled details of its new identity fraud prevention measures, which will be part of the FAFSA starting Sunday, April 26, along with a one-time identity fraud screen of all previously submitted 2026-27 FAFSAs. 

Under these new real-time identity fraud prevention measures, which were previewed at the in-person Federal Student Aid (FSA) conference in March, ED will screen and assess each FAFSA for fraud risk before it is submitted. ED claims these new measures will allow legitimate students to proceed without any slowdown in the FAFSA submission process, and only a “small proportion” of applicants determined to a high fraud risk will be required to complete additional steps to confirm their identity. 

All applicants will still be able to submit a FAFSA and have it processed, and Institutional Student Information Records (ISIRs) will be sent to selected schools and state agencies. However, if ED is unable to confirm a high risk applicant’s identity within the online FAFSA workflow, the applicant’s ISIR will be placed in a rejected status. Rejected ISIRs will include new reject and comment codes, as listed in the electronic announcement and included in the FAFSA Specifications Guide. Schools are not required to take any action on these rejected ISIRs, but if contacted by the student, must complete verification using the procedures associated with V4 verification in order to resolve the record’s rejected status.

Additionally, previously submitted 2026-27 FAFSAs will also be screened under these new identity fraud prevention measures. ED clarified that applicants will not need to do anything additional to their already submitted FAFSA. However, since any applicant determined to be a high fraud risk is unable to complete real-time identity confirmation, the screening will likely result in additional records being selected for V5 verification. Schools must follow the regular guidelines for V5 verification in order to verify these records. 

ED noted that this is a one-time screening to review already-submitted FAFSAs before the real-time fraud detection is implemented. In the future, ED expects overall selection rates for V4 and V5 verification to be “minimal.”

“The Department recognizes and appreciates the critical role FAAs have played to date, as well as the additional burden this work has placed on institutions,” the electronic announcement reads. 

Under these new fraud prevention measures, applicants will be placed into four categories assessing their fraud risk: low, moderate, high, and highest. Applicants with a low or moderate fraud risk will not be required to provide additional identity information and will not have their ISIR rejected. However, ED noted that those with a moderate risk marker will have Comment Code 353 added to their ISIR, notifying schools of an elevated risk. Schools will not be required to take any action on applicants with a moderate fraud risk. 

Applicants with a high-risk marker will have their ISIR rejected and will be prompted to complete an additional identity confirmation process in real-time within the FAFSA. Applicants with the highest risk marker will not be offered the option to complete identity confirmation during the online FAFSA process and will have their ISIR rejected, with Reject Code 75 and Comment Code 357.

ED outlined what the real time identity confirmation would look like under the FAFSA process. Applicants placed in the high-risk category will be asked to confirm their identity by presenting documentation and completing a brief, live camera check. The applicant will need to complete this step on a mobile or tablet device with a camera. Applicants who begin the FAFSA on a desktop or other non-mobile device will be provided with a QR code to continue the process on a mobile device. 

For their documentation, applicants will be asked to present one valid form of government-issued identification – such as a driver’s license, passport, tribal identification card, or permanent resident card – on camera for a photo. ED noted that this process is automated and in real time. Applicants will have a “short window” to retrieve their documentation if it is nearby; however, ED warned that the session is designed to be completed in one sitting and cannot be paused or resumed later.

Applicants who cannot provide documentation during this timeframe will still be able to submit their FAFSA, but their ISIR will be processed with Reject Code 74 and Comment Code 355. These applicants will need to contact their selected school’s financial aid office, and the school will need to complete the identity verification process. 

The EA reiterates that any record rejected under this new identity verification process has a high likelihood of being fraudulent. However, these new identity fraud prevention measures are not perfect, ED warned, and therefore included guidance on how financial aid administrators (FAAs) can resolve identity confirmation issues for legitimate students with rejected status. 

Starting on Sunday, May 3, schools will be able to assist applicants in resolving the rejected status of their applications. FAAs must follow the guidelines for information to be verified and acceptable documentation for resolving identity verification as published in the Nov. 26, 2025, Federal Register notice, ED wrote. From there, the FAA must resolve the reject code by reporting the result of the identity confirmation using the new field “FAA Fraud Override” in the FAFSA Partner Portal (FPP), which will generate a valid ISIR that contains a calculated Student Aid Index and Pell Grant eligibility, pending there are no other issues. 

Once this functionality is available, FAAs must submit the fraud override indicator through the FPP. However, ED noted that it is working to enable corrections via the Electronic Data Exchange but did not provide a specific timeline for when this would become available. 

ED clarified that FAAs are not required to take action on ISIRs with any of the new fraud-related reject or comment codes if the student is not enrolled, is not a federal student aid recipient, or is otherwise ineligible to receive Title IV funding.

Overall, ED expects that FAAs will not need to take any action on the “significant majority” of rejected applications under these new fraud-prevention measures. 

Along with this electronic announcement, ED also announced that it released an updated specifications guide with new reject and comment codes. ED noted that it is adding Comment Code 360, which will appear on ISIRs when a technical issue prevents ED from completing a standard screening for an applicant’s FAFSA form. The department stated that it does not anticipate using this code “often” and the specifications guide confirms no action by the school is required. 

Stay tuned to Today’s News for more updates on these FAFSA fraud prevention measures, including a new “Off the Cuff” episode on Friday with Aaron Lemon-Strauss, ED’s FAFSA program executive director. On the “Off the Cuff” episode, NASFAA’s Melanie Storey and Karen McCarthy discuss this electronic announcement, and ask Lemon-Strauss pressing questions on how these new fraud prevention measures will impact financial aid offices. 

Publication Date: 4/16/2026

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