Articles

Client Alert: New Title VI Coordinator Law: What Every New York Higher Ed Institution Needs to Know Now

Date: September 17, 2025
On August 26, 2025, New York Governor Kathy Hochul signed into law A5448B/S4559B, which amends New York Education law, adding §6436-a, requiring every college and university in New York State to appoint a Title VI anti-discrimination coordinator (similar to the Title IX coordinator and their role). The Title VI coordinator’s role is to ensure compliance with Title VI of the federal Civil Rights Act of 1964, which prohibits discrimination on the basis of race, color, or national origin, including shared ancestry or ethnic traits, in programs and activities of any entity that receives federal financial assistance. Governor Hochul said the law is meant to “combat antisemitism and all forms of discrimination head-on.”  
 

Why This Law Now?

The legislation was enacted in response to rising antisemitism on college campuses. Further, while most universities have Title IX infrastructure for sex discrimination, Title VI protections have sometimes been fragmented or poorly understood. Lawmakers heard from students that they did not always know where to report Title VI violations or what legal protections against discrimination they had. Another lawmaker who co-sponsored the bill noted that “the appointment of a designated TitleVI Coordinator ensures that when violations occur, students have clear points of contact and the colleges and universities have clear paths for corrective action, with a dedicated person responsible.”
 

What Does the Law Specifically Require?

The law requires that colleges and universities appoint a dedicated person to handle Title VI complaints to ensure compliance with Title VI. But the law also imposes annual notification, training, and recordkeeping requirements. Specifically, the law requires:
 
  1. The New York State Division of Human Rights to develop model training materials for students and employees to support compliance, in coordination with New York-based higher education institutions;
  2. The Title VI coordinator to notify, annually, all students and employees of the institution’s policies and procedures for reporting discrimination and harassment; and
  3. The institution to conduct training annually for students and employees, commencing with the first full academic year after the law takes effect, either using the State’s model training or an institutionally developed equivalent. The Title IV coordinator and their designees must also be trained in their duties and responsibilities under this law and Title VI.
The Title VI coordinator’s annual notification must include: (1) the institution’s nondiscrimination policy statement; (2) website links to all policies and procedures for reporting discrimination and harassment to the institution; (3) the contact information of the Title VI coordinator; and (4) any other information the Title VI coordinator and the institution deem necessary.

The Title VI coordinator receiving a complaint of discrimination or harassment must: (A) offer supportive measures for the student or students making a complaint; (B) notify any students who report conduct that may reasonably constitute discrimination or harassment under Title VI of the institution’s policies and/or procedures; and (C) ensure there is a process for investigation and resolution of complaints consistent with obligations under federal and state law. The intent of the law is to provide greater uniformity across institutions so that every student has a clear point of contact, and there is a predictable process for investigation and remedial action. The Title VI coordinator is also responsible for recordkeeping, including,but not limited to, those records related to any reports and complaints of discrimination and harassment, and records of training attendance and materials.
 

When Does the Law Take Effect?

The law takes effect on August 26, 2026.
 

What Should Employers Do Now?

Here are some next steps that higher education institutions should consider to ensure readiness and compliance:
  1. Define the Role & Hire/Designate: Identify who will fill the Title VI Coordinator role (could be existing HR, EEO, or Diversity & Inclusion personnel, but with a clear role definition). Ensure the role has enough authority, resources, and access to leadership to effect change.
  2. Review and Update Policies & Procedures: Audit existing non-discrimination policies; ensure they clearly cover race, color, national origin, including “shared ancestry or ethnic characteristics.” Map out complaint/grievance procedures; check that reporting lines are clear.
  3. Training Development & Implementation: Review the NYS Division of Human Rights’ model training, once issued, and determine whether your institution wants to use the model training or customize it; roll out training for the Title VI coordinator and any designees, administrators, HR, students, faculty, and other employees.
  4. Communications & Awareness: Inform campus community (students, faculty, staff) about the new coordinator role, how to reach the coordinator, and what protections exist; integrate into student orientation, faculty onboarding, and ongoing education.
  5. Monitoring, Data & Reporting: Implement record-keeping for complaints and reports: date, nature, outcome, remedial actions, and training attendance and training materials provided; ensure the Title VI Coordinator has administrative support, investigative capacity, and visibility.

Conclusion

This law makes New York the first state to require every higher education institution to have a designated Title VI Coordinator. Getting ahead—defining the role, ensuring policies and training for the Title VI coordinator, students, faculty, and other employees are tight, and ensuring students know their protections—will minimize legal exposure and reinforce trust within campus communities. Please reach out to your Whiteford Labor & Employment attorney for advice and guidance on these new legal requirements and any related policies and training.
The information contained here is not intended to provide legal advice or opinion and should not be acted upon without consulting an attorney. Counsel should not be selected based on advertising materials, and we recommend that you conduct further investigation when seeking legal representation.