The Fractional Digest · April 2026
Title IX: what applies today
After two years of regulatory whiplash, a clear read on which rules actually govern your program right now.
How we got here
The 2020 Title IX regulations established a detailed grievance framework, formal complaints, defined roles, and, for postsecondary institutions, live hearings with cross-examination. In 2024, a new rule rewrote much of that framework and took effect for the 2024–25 year. Litigation followed almost immediately, and injunctions blocked the 2024 rule in a long list of states, leaving institutions to operate under different rules depending on where they sat.
The vacatur
In January 2025, a federal court vacated the 2024 rule nationwide. The practical effect: the 2020 Title IX regulations returned to force across the country, and the state-by-state patchwork collapsed back into a single national standard. As of this writing, the 2020 rule is what governs.
What applies today
That means the framework many coordinators spent 2024 preparing to leave is the framework in force: the formal complaint process, the specific definition of sexual harassment, the defined roles for coordinator, investigator, and decision-maker, and, for colleges and universities, the live-hearing-with-cross-examination requirement. If your program shifted toward 2024-rule procedures, the task now is to confirm that your policy and your practice both reflect the 2020 rule.
Don’t run a hybrid by accident
The most common risk we see isn’t choosing the wrong rule, it’s running a process that’s half one and half the other because the transition never fully happened. Read your published policy against what your team actually does. Where they diverge, a reviewer will find it. Align them before the next complaint, not during it.
Watch this space
Regulatory direction on Title IX has changed with administrations, and it can again. The programs that weather that don’t bet on a single rule staying put, they build a process that documents fairness and jurisdiction on its own terms, so that whatever framework is in force, the file holds up. This is the one area where “what we did last year” is the most dangerous assumption on the desk.
The Fractional Digest is practical guidance, not legal advice. Regulatory frameworks change frequently, verify the current state of the law with your counsel or regulator before acting.
