Question · Title VI

How do we audit an AI admissions tool for Title VI disparate impact?

Title VI bars discrimination based on race, color or national origin in federally funded programs.

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AboutTitle VI

Legal forceBinding on recipients of federal financial assistance

Applies from2 Jul 1964

Checked21 Oct 2026

01 / The answer

The short answer

Unequal results alone no longer violate ED's Title VI rules: ED removed disparate-impact liability effective July 24, 2026, and DOJ removed its own in December 2025. Title VI still bars intentional discrimination, and the Supreme Court barred race-conscious admissions in SFFA v. Harvard (2023). So audit the tool to confirm it does not use race, color or national origin, or inputs chosen to stand in for them, and compare outcomes by group to catch problems early. Keep records of the inputs, testing and fixes.
Title VI · checked 21 Oct 2026

02 / The rule

What Title VI requires

Title VI bars discrimination based on race, color or national origin in federally funded programs. Since July 24, 2026, ED's regulations reach only intentional discrimination: disparate-impact liability has been removed, so AI tools draw scrutiny mainly when they treat students differently by race or national origin, or when schools ignore race-based harassment.

01Do not use AI tools that treat students differently on the basis of race, color or national origin.
02Respond to known race or national-origin harassment, including AI-generated content such as deepfakes targeting students.
03Give the required assurance of Title VI compliance as a condition of federal funding (34 CFR 100.4).
04Keep compliance records and give OCR access to them on request (34 CFR 100.6).

03 / Records

Records to keep

01Vendor review of whether AI tools use race or national-origin data
02Harassment complaint and response records, including AI-generated content
03Signed Title VI assurance of compliance
04Outcome monitoring by student group for AI-driven decisions

Optional evidence · where Planisphere fits

Keep a record anyone can check

When your team meets a duty, Planisphere can seal the event it reports as a receipt.

01 · Your teamRecord the event

A disclosure shown, a review signed, a model change approved: the event your system reports.

02 · PlanisphereSeal it

The event becomes a sealed receipt, dated and attributed to whoever is signed in.

03 · AnyoneCheck it

Paste the receipt into Verify. No account or key.

A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.

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