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Foreign Gifts and Contracts Disclosures Draft Form 2026

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Summary

The Department of Education has published a draft revised Foreign Gifts and Contracts Disclosures form (1845-0172) for public comment. The 2026 draft version modifies the current 2023 disclosure document, with attachments providing comparison details. The form implements disclosure requirements under 20 USC 1011f (Section 117 of the Higher Education Act) governing foreign gifts and contracts at covered institutions.

What changed

The Department of Education has released a draft revised Foreign Gifts and Contracts Disclosures form (1845-0172) dated 4.14.26, amending the current 2023 version. The draft includes attachments comparing the two versions and provides a bulk upload template for institutional use. Section 117 of the Higher Education Act (20 USC 1011f) requires covered institutions to disclose gifts and contracts from foreign sources exceeding specified thresholds.

Affected parties—primarily colleges, universities, and other higher education institutions receiving foreign gifts or contracts—should review the proposed changes carefully and prepare comments. Institutions should assess how the revised form may alter their reporting obligations and ensure their gift acceptance and disclosure processes align with the updated requirements once finalized.

What to do next

  1. Review draft 2026 Foreign Gifts and Contracts Disclosures form
  2. Submit public comments on the proposed revisions before the comment close date
  3. Update internal compliance procedures based on final form requirements

Archived snapshot

Apr 15, 2026

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Content

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Attachments 4

1845-0172 Foreign Gifts and Contracts Disclosures 60D 2026 Draft 4.14.26

Download

Bulk Upload Template

Download

Comparison of Disclosure Documents 2023 v 2026

Download

USCODE-2017-title20-chap28-subchapI-partB-sec1011f

Download

Named provisions

1845-0172 Foreign Gifts and Contracts Disclosures 20 USC 1011f Section 117

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Last updated

Classification

Agency
ED
Instrument
Consultation
Legal weight
Non-binding
Stage
Draft
Change scope
Substantive
Document ID
ED-2026-SCC-1354-0003
Docket
ED-2026-SCC-1354

Who this affects

Applies to
Educational institutions
Industry sector
6111 Higher Education
Activity scope
Foreign gifts disclosure Foreign contracts reporting Higher education compliance
Geographic scope
United States US

Taxonomy

Primary area
Education
Operational domain
Compliance
Topics
Government Contracting Financial Services

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