New York is the First State to Pass Title VI Legislation Requiring Every College and University to Appoint a Title VI Coordinator and Take Certain Actions
Update: Sept 4, 2025
READ THE COMPREHENSIVE ANALYSIS HERE
GO TO TRAINING PAGE FOR: Title VI Obligations for New York State Higher Education.
By Joseph Storch, Senior Director of Compliance and Innovation, Grand River Solutions
August 26, 2025
On Tuesday, August 26th, New York State Governor Kathy Hochul signed into law an important update to New York State Education Law Article 129-A. The new law codifies the nation’s first statewide requirement to identify a Title VI Coordinator and take certain actions in support of preventing and responding to certain types of discrimination and harassment.
This new law is specific to Title VI of the 1964 Civil Rights Act, which prohibits discrimination on the basis of race, color, or national origin.
A Title VI Coordinator on Every College Campus
The new law will create a new section of Education Law Article 129-A called 6436-a. Article 129-A (like Education Law Article 129-B) applies to most colleges and universities in New York State, specifically, “every college chartered by the regents or incorporated by special act of the legislature and which maintains a campus.” (6430). This includes all SUNY and CUNY campuses, all CICU and APC campuses, and a few other institutions; over 200 institutions of higher education.
Within 90 days of the effective date (which appears to be 455 days after Governor’s signature), covered institutions must designate a Title VI Coordinator. The Coordinator will have a number of specified tasks, but most importantly will be the designated “owner” and point of contact for all elements of Title VI compliance. The Title VI Coordinator may have designees, but the Coordinator shall be ultimately responsible for coordinating and overseeing compliance.
Disclosures of Discrimination and Harassment
When a person discloses discrimination or harassment on the basis of race, color, or national origin, the Title VI Coordinator or designee must:
- Offer supportive measures;
- Notify reporting individuals of the institution’s policy and process on investigating and adjudicating such cases; and
- Ensure there is a process for investigations and resolutions of such disclosures.
General and Annual Requirements
The legislation stipulates requirements for notifications, training, and record-keeping.
The Title VI Coordinator must notify all students and employees annually of policies and procedures for reporting discrimination and harassment, including:
- The discrimination policy statement;
- Internet links to all relevant policies and procedures;
- Contact information for the Title VI Coordinator (and potentially disclosure designee(s)); and
- Other information deemed necessary.
The legislation requires training be distributed to all students and employees. The law will require that the Title VI Coordinator develop “training to promote equal access and participation.” Training is to be delivered annually to all students and employees in the first full academic year after the effective date. The language of the law uses the term “delivered,” which we believe to be equivalent of “made available” or “provided.”
The Title VI Coordinator and any designees or Deputy Coordinators must be trained in all of their obligations and the requirements of the law. The law sets out no temporal requirements for the training, either in how long the training must be or how often it must be repeated.
The Title VI Coordinator shall be responsible for appropriate record keeping related to discrimination and harassment complaints, including all records related to assessment of reports and actions an institution took under the laws. They must also maintain records of training attended and the materials.
We’ve also written a more comprehensive analysis and are providing training for NY Higher Education Leadership. See below links:
READ THE COMPREHENSIVE ANALYSIS HERE
GO TO TRAINING PAGE FOR:Title VI Obligations for New York State Higher Education.
Want to talk about the new requirements? Contact us or book time with Regional Director Martha Compton.