New Federal Anti-Hazing Requirements for College Campuses

Covered institutions must begin collecting data regarding such “hazing incidents” as of January 1, 2025, and must begin including such data in the ASR starting October 1, 2026. “Hazing incidents” are defined as:

• any intentional, knowing or reckless act committed by a person (whether individually or in concert with other persons) against another person or persons regardless of the willingness of such other person or persons to participate, that:

-  is committed during an initiation into, an affiliation with or the maintenance of membership in a student organization; and

-  causes or creates a risk, above the reasonable risk encountered during participation in the school or the organization (such as the physical preparation necessary for participation in an athletic team), of physical or psychological injury.

Examples of hazing provided in the Act include:

• whipping, beating, striking, electronic shocking, placing of a harmful substance on someone’s body, or similar activity;
• causing, coercing or otherwise inducing sleep deprivation, exposure to the elements, confinement in a small space, extreme calisthenics, or other similar activity;
• causing, coercing or otherwise inducing another person to consume food, liquid, alcohol, drugs, or other substances;
• causing, coercing or otherwise inducing another person to perform sexual acts;
• any activity that places another person in reasonable fear of bodily harm through the use of threatening words or conduct; and
• any activity against another person that includes a criminal violation of local, state, Tribal or federal law or that induces, causes, or requires another person to perform a duty or task that involves such a criminal violation.

The term “student organization” is broadly defined as an organization at the school (such as a club, society, association, varsity or junior varsity athletic team, club sports team, fraternity, sorority, band or student government) in which two or more of the members are enrolled students, whether or not the organization is established or recognized by the school.

Policy and Prevention Program on Hazing: June 23, 2025
The Act also requires colleges and universities to take the following actions by June 23, 2025:

• Statement of Current Hazing Policies. Publish a statement of current policies related to hazing (as defined by the school), how to report incidents of such hazing, and the process used to investigate such incidents of hazing, and information on applicable laws on hazing.
• Statement Regarding Hazing Prevention and Awareness. Publish a statement of policy regarding prevention and awareness programs related to hazing (as defined by the school) that includes a description of research-informed-campus-wide prevention programs designed to reach students, staff and faculty. The statement must include the above-referenced statement of current policies and primary prevention strategies intended to stop hazing before hazing occurs, which may include skill building for bystander intervention, information about ethical leadership and the promotion of strategies for building group cohesion without hazing.

Campus Hazing Transparency Report: beginning July 1, 2025
Finally, the Act requires covered institutions to begin collecting data related to hazing violations by July 1, 2025, and develop, publish and update a Campus Hazing Transparency Report (CHTR) in a prominent location on its website by December 23, 2025. The reporting required by the CHTR is different in scope than the ASR. It must summarize findings of any established or recognized student organization found to be violation of the institution’s standards of conduct relating to hazing. Notably, the geographic scope of violations that must be summarized in the CHTR is broader than the institution’s “Clery geography,” and includes any finding of a violation, irrespective of where it occurred.

In addition to information regarding the availability of hazing statistics, policies and applicable laws, the CHTR must include the following details regarding any hazing violation:

• The name of the student organization;
• A general description of the violation that resulted in a finding of responsibility, including whether the violation involved the abuse or illegal use of alcohol or drugs, the findings of the institution, and any sanctions placed on the student organization by the institution, as applicable; and
• The dates on which: (a) the incident was alleged to have occurred; (b) the investigation into the incident was initiated; (c) the investigation ended with a finding that a hazing violation occurred; and (d) the institution provided notice to the student organization that the incident resulted in a hazing violation.

At least twice a year, the CHTR must be updated to include, for the period beginning on the date on which the CHTR was last published and ending on the date on which such update is submitted, each incident involving a student organization for which a finding of responsibility is issued relating to a hazing violation. This summary of violations must be maintained for five calendar years from the date of publication.

The CHTR may consist of an existing report that meets the above requirements and may include any additional information required to be reported under state law.[1] The CHTR should not include any personally identifiable information of students.

If you have questions about your institution’s compliance obligations under the Act, please contact the authors of this client alert for a consultation.

^{[1] California colleges and universities should be aware that a state Stop Campus Hazing Act was enacted in 2024, with an effective date of January 1, 2026. You can contact the authors of this client alert for information regarding the California Stop Campus Hazing Act requirements.}