Published by Fractional Coordinator, Inc. | December 2025

As 2025 winds down, remember: the 2024 Title IX regulations remain vacated. OCR continues to enforce the 2020 rule pending new rulemaking. What does your compliance plan look like going into 2026?

While much attention has focused on the vacated 2024 Title IX rule , another development has quietly reshaped obligations for schools and universities: OCR’s recognition that online or digital sexual harassment falls under Title IX.  Non‑consensual photo sharing, group‑chat bullying and tech‑enabled stalking can deprive students of educational access and trigger your institution’s duty to respond .  As we head into 2026, the challenge is clear: how do we translate Title IX’s promise of equity into a digital world?

A Legal Framework with Teeth

Title IX’s core purpose is to protect students from sex discrimination.  Under the 2020 regulations, schools must investigate harassment that is severe, pervasive and objectively offensive, offer supportive measures and provide due process for all parties.  OCR’s January 2025 guidance clarified that these obligations extend to digital spaces: unwelcome conduct via social media, messaging apps or other online platforms can meet the definition of sexual harassment when it targets students.

The guidance doesn’t create new rules, it applies existing standards to new contexts.  Yet this seemingly simple extension has far‑reaching implications.  Institutions that fail to address online harassment risk violating federal law.

An Uneven Landscape of Readiness

Over the past year, responses to digital harassment have varied widely.  Some colleges have conducted comprehensive audits, updated policies to mention social media, trained investigators on handling digital evidence and created clear reporting pathways.  Others, often with limited resources, still rely on outdated policies that focus solely on in‑person misconduct.

Students feel this disparity acutely.  In some classrooms, support staff quickly address cyberbullying and non‑consensual image sharing.  In others, victims are told that “it didn’t happen on campus” and are left to navigate harassment alone.  The uneven landscape mirrors broader compliance gaps in Title IX and underscores the need for consistent, proactive strategies.

The Weight of Old Frameworks

Many institutions built their Title IX procedures before anyone contemplated digital harassment.  Some policies still rely on the vacated 2024 rule; others reflect pre‑2020 practices.  Untangling these layers requires careful legal analysis and a commitment to updating policies, training materials and investigative protocols.

Complicating matters, executive orders issued in 2025 signal a shift away from diversity, equity and inclusion initiatives.  Schools that integrated DEI language into Title IX policies must decide whether those commitments endure.  Meanwhile, courts continue to interpret the scope of Title IX, meaning today’s guidance could evolve again.

A Cultural Shift in What Compliance Means

Addressing digital harassment isn’t just a legal obligation; it reflects a cultural shift in how we define safety and equity.  Title IX compliance can no longer live in a single coordinator’s office.  It must permeate student affairs, IT departments, academic programs and campus communications.

Forward‑thinking institutions are forming cross‑functional committees, embedding digital misconduct examples into syllabi and faculty training, and integrating harassment reporting mechanisms into learning platforms.  These efforts signal a move from reactive investigations to proactive prevention.

A Deadline That Signals Something Larger

Unlike the ADA’s concrete deadlines for web accessibility, there’s no statutory date for digital harassment compliance.  However, a new Title IX rule could arrive in 2026, and courts may continue to interpret online conduct.  Administrators should view the coming months as an opportunity to strengthen systems rather than check a box.

Key actions before 2026:

• Audit your policies to explicitly cover online harassment and align with the 2020 rule.

• Train investigators and decision‑makers on collecting and evaluating digital evidence .

• Educate your community about what constitutes online misconduct and how to report it.

• Monitor federal developments, subscribe to OCR updates and review the Federal Register to stay informed about potential rule changes.

Partnering with Fractional Coordinator

Fractional Coordinator, Inc. helps public colleges, universities and school districts navigate the rapidly changing Title IX landscape.  We conduct policy audits, update grievance procedures, design digital‑harassment protocols and train staff and faculty to respond effectively.  Our goal is to help institutions build durable systems that protect students in classrooms, residence halls and online communities.

To learn more about our services or schedule a consultation, visit www.fractionalcoordinator.com or email support@fractionalcoordinator.com.