U.S. Department of Education launches new portal and “Public Transparency Dashboard” related to Section 117 foreign gift and contract reporting

New Section 117 Portal

On December 18, 2025, ED published a recording of its December 15 “Using the New Section 117 Reporting Portal” training webinar. Key takeaways from the training webinar include the following:

1. Current Section 117 guidance and the portal data fields generally remain the same. ED confirmed that there are no substantive changes to the data being collected through the portal; institutions can expect to collect and report the same types of information. However, the new portal introduces certain capabilities that may affect how an institution prepares and submits reports. For example, the new portal incorporates a “Valid Country Names List” from which institutions must select the appropriate attributable country from a drop-down menu; certain countries previously used in Section 117 reporting no longer appear, including Hong Kong.
2. The new portal is intended to make the Section 117 process easier and more efficient, and ED will share training resources to support the transition. ED published three user guides concurrent with the training webinar recording (Account Management, Reviewing Reports, and Disclosure Reporting) and indicated in the training webinar that it will share additional resources on an ongoing basis, including training videos.
3. Institutional personnel can collaborate within the new portal to prepare and submit Section 117 reports. The new portal permits an institution to designate assigned roles for users. As a result, an institution may choose to have one person handle all aspects of Section 117 reporting, or leverage multiple users – for example, one or more individuals to input data while others review, approve, and submit. The new portal also tracks changes to data inputs and includes a “comments” capability for internal institutional discussion.

Public Transparency Dashboard

ED describes in its training webinar that the Public Transparency Dashboard helps to “visualize” Section 117 data that has been collected and previously published in downloadable spreadsheets (which also remain available via the “Downloads” tab on the new webpage). The dashboard currently reflects both aggregate and institution-specific data reported as of January 31, 2025.

Notably, the dashboard includes a ranked listing of institutions by the cumulative dollar amount of gifts and contracts reported to ED as of January 31, 2025. The following data points appear when an institution’s name is clicked:

• “University funding rank” – The institution’s rank out of 527 reporting institutions based on the total dollar amount reported. (The www.ForeignFundingHigherEd.gov landing page lists the “top 10” institutions, and additional institutions can be viewed by using the search function or clicking through the list.)
• “Total funding” – The total dollar amount of foreign gifts and contracts reported by the institution. (This data point is also viewable from the landing page for the “top 10” institutions.)
• “Transaction count” – The total number of foreign gifts and contracts reported by the institution.
• “Funding by country” – A data breakdown of the top 10 countries to which the gifts and contracts reported by the institution are attributable. This information is listed in order of total dollar amount (highest to lowest) and also includes the total number of reported gifts and contracts attributable to each country.
• “Transaction types” – A data breakdown of each transaction type (i.e., contract, gift, restricted contract, restricted gift) that reflects the total dollar amount, number of reported gifts and contracts, and corresponding percentages for each transaction type.

While ED has not issued any public statements to date that substantively characterize the data reflected in the Public Transparency Dashboard, others have. For example, on January 5, 2026, the U.S. House Select Committee on the Chinese Communist Party issued a press release focused on reported amounts attributable to China and Hong Kong; and used the data as support for its efforts to pass additional legislation to “protect students and the taxpayer-funded research being done on our nation’s campuses.”

Next steps

By statute, Section 117 reports are next due January 31, 2026. ED has confirmed that Section 117 reports are timely if submitted no later than Monday, February 2, since January 31 falls on a weekend. ED underscored in its January 2 Electronic Announcement that “[f]ailure to comply with the reporting requirement could result in an enforcement action.”

Our Education practice remains available to assist institutions with Section 117 and other foreign gift and contract reporting requirements. Please contact a member of our team if you have questions.

Authored by Stephanie Gold, Joel Buckman, Megan Wilson, and John Powers.