Selected for FAFSA Verification: What to Send in 2026-27
The verification request from your financial aid office lists what it wants. It does not explain why one family is asked for a single signed statement and the next is asked to stand in front of a phone camera, and when you go looking for that explanation you land on pages describing the IRS Data Retrieval Tool — an optional button on a form that no longer exists. The 2023-24 FAFSA was the last one that had it. What carries your tax data now is FA-DDX, and it changed which questions a school can even ask you in 2026-27.
This is the 2026-27 award year — enrollment between 1 July 2026 and 30 June 2027. Its identity half moved twice inside that year: the screening described below went live on 26 April 2026, and the announcement carrying its codes was revised again on 21 August 2026, two days before these sources were read. Several of the rules that follow are your school's to set rather than the Department's, and those are flagged where they come up, with the phrase worth searching for on the aid office's own site.
The tool most published advice still describes was retired three cycles ago
The FUTURE Act amended section 6103 of the Internal Revenue Code so the IRS could disclose tax data straight to Federal Student Aid. What the two agencies built out of that is the FUTURE Act Direct Data Exchange, and the 2024-2025 Federal Student Aid Handbook put the succession plainly: the FA-DDX "replaces the IRS Data Retrieval Tool (IRS-DRT) and will be used beginning with the 2024-25 award year."
Three differences matter to you. The old tool was optional; consent and approval for the exchange is now a condition of eligibility for federal student aid, which is why a form stalls when one contributor never opens the invitation. The old tool showed you the numbers it pulled and let you edit them; the new one does neither. The Federal Register notice for this cycle, published 26 November 2025 at 90 FR 54316, says the tax information "will not be viewable by the student and other contributors," then draws the consequence: "IRS data that is transferred and used in the Pell Grant eligibility determination and/or Student Aid Index (SAI) calculation cannot be edited and therefore is not subject to any verification procedures." Data arriving that way is not something a school can ask you to prove.
If you are still assembling the form rather than answering a request about it, the consent and contributor sequence sits in what to gather before you open the FAFSA.
What the exchange already settled, and the two things it gets wrong
Because of that, a verification request in 2026-27 should be narrow. Dear Colleague Letter GEN-25-10, issued 26 November 2025, tells schools they are not required to collect a Tax Return Transcript or a signed copy of the 2024 income tax return if that information was successfully transferred through the exchange and used in the Pell Grant eligibility determination or the SAI calculation. What still needs paper is what the exchange could not deliver: returns filed with a U.S. territory or a foreign government, self-employment figures it failed to match, and foreign income exempt from federal taxation, which appears on the list as an item that always requires documentation.
Then there is the rollover. A qualified rollover from one retirement account to another is not taxable and should not count as untaxed income — but neither an IRS transcript nor the transferred data flags a distribution as a rollover. So a parent who moved a 401(k) into an IRA during 2024 can end up with that whole amount sitting in the file as untaxed income, inflating the Student Aid Index, with nothing visible on the form to argue against. The 2026-2027 Application and Verification Guide is blunt that rollovers still have to be verified even when the number itself arrived as federal tax information. A signed, dated statement giving the rollover amount clears it, and so does the word rollover written beside the item on the return or transcript, signed and dated by the filer. Nobody will ask you for either one if the office does not know the rollover happened.
Amended returns behave the same way. FA-DDX transfers original tax information only, and there is no indicator on the form saying a 1040-X was ever filed. If one was, say so — the school has to correct the record and have the calculation re-run. That is a different route from the one you take when your income has simply fallen since 2024, which is professional judgment.
V1, V4, V5, and the three groups that do not exist
Your FAFSA Submission Summary marks selection with an asterisk beside the SAI and a line in the Application Status section. The ISIR your school receives carries more: a verification tracking flag set to "Y" and a tracking group. Three are in use — V1, V4 and V5. Groups V2, V3 and V6 are reserved by the Department for future use and are not in circulation, so a page explaining what V6 asks for is explaining a selection rule that was retired years ago.
V1 is what the Handbook calls the Standard Verification Group, covering financial items and family size. V4 is identity alone. V5 is both, and V5 is the one that stops everything, because no Title IV money may be disbursed for the award year until it is satisfactorily completed. Records move between groups. A correction or new information can push a V1 or V4 record into V5, and in that case only the parts you had not already finished have to be redone.
Two footnotes with real consequences. A student who is confined or incarcerated is not required to complete verification at all when selected for V1, and under V4 or V5 only identity has to be confirmed, with an official ID issued by the correctional facility acceptable as documentation. And your school may select you itself, independently of the Department, for any item it has reason to doubt or that its written policy covers. Those students face the same deadlines, tolerances and interim disbursement rules as everyone selected by the Department — with one limit in your favor. A school-selected item that has no bearing on federal eligibility cannot be used to hold up a Title IV disbursement. The Handbook's example is home equity in a family's primary residence, which the SAI formula excludes from assets in the first place.
The V1 list, and the parts you may not have to prove
For tax filers, the 2026-27 items are adjusted gross income, income earned from work, U.S. income tax paid, untaxed portions of IRA distributions, untaxed portions of pensions, IRA deductions and payments, tax-exempt interest income, education credits, foreign income exempt from federal taxation, and family size. For non-filers the list collapses to two: income earned from work, and family size.
Non-filers submit a signed and dated statement certifying that no 2024 return was required, together with the sources and amounts of what supported the household, plus a Form W-2 for each source of 2024 employment income. Notice what is absent. An IRS Verification of Non-filing Letter is not on that list. The 2026-27 documentation table calls for verification of non-filing only where the person would file with a tax authority other than the IRS, dated on or after 1 October 2025, and it exempts dependent students outright. A worksheet demanding an IRS non-filing letter from a dependent student's non-filing parent is asking for something the federal rule does not require.
Family size carries its own exemptions. Where the number came straight from the IRS and was used, it is not verified. Beyond that, a dependent student reporting a family size of two with a single, divorced, separated or widowed parent — or three with parents who are married, or unmarried and living together — does not have to document it. An independent student reporting two while married, or one while single, divorced, separated or widowed, is in the same position.
The worksheet itself is not a federal form. The Department publishes suggested text in Appendix A of GEN-25-10, and schools may adopt it, rewrite it, or build their own, so long as they do not put the Department's seal on it. That is why two campuses send two different-looking packets for the same tracking group, and why the instructions on one do not answer questions about the other.
Identity now means a camera, a notary, or a vendor with a NIST label
The Statement of Educational Purpose is gone. GEN-25-10 states that institutions can no longer require applicants to submit one. If a form in front of you still contains that paragraph, it is a leftover from a template nobody updated.
Four methods replaced it. GEN-25-10 names them, and the Department's program integrity questions and answers on verification, whose newest identity entries are dated 10 August 2026, works through the edge cases. Appearing in person with an unexpired, valid, government-issued photo ID is the preferred method. Verification by a third party meeting the National Institute of Standards and Technology Identity Assurance Level 2 standard is open to everybody, including students who could easily walk into the office. The other two — a copy of an ID acknowledged in a notary statement, or a live video call with an institutionally authorized person — are available only where the school determines the student cannot appear in person. And the notary has to be face to face: GEN-25-10 says flatly that "online notarization is not an acceptable method for our requirements."
The ID rules trip people up in both directions. A student ID from a state university or college does not count, and neither does a military ID, because 18 U.S.C. 701 prohibits photocopying it. The list of acceptable issuers is wider than most people assume, though: the federal government, any of the 50 states, the District of Columbia, Puerto Rico, a federally recognized tribe, and the territories and freely associated states all qualify, and an ID marked "not for federal identification" is still acceptable here. Once your school makes its first request for documentation on a record the Department placed in V4 or V5, it has 60 days to report the result, and 30 days to correct a result it already sent.
Why so many students started meeting these rules traces back a year, to an announcement of 6 June 2025, APP-25-16. Facing organized identity fraud aimed at Pell, the Department widened V4 selection to first-time applicants expected to receive aid that summer and put the number at "roughly 125,000 students." That estimate covers summer 2025 under the 2025-26 award year; nothing comparable has been published for 2026-27, and the same announcement said it expected no change at all to income-based V1 selection.
Since 26 April 2026, the screening starts while you are still on the form
Electronic announcement APP-26-03, posted 15 April 2026 and revised on 21 August, describes a real-time identity fraud screen built into the FAFSA form itself and live since 26 April 2026. Every applicant is scored while completing the form and lands in one of four risk categories.
Low risk produces nothing at all. Moderate risk adds Comment Code 353 to the ISIR — no action is required from you, though schools are encouraged to run their own identity checks on those records. High risk triggers an identity confirmation step inside the online form: one government-issued ID and a live camera check, which must happen on a phone or tablet. Start on a laptop and you are handed a QR code to continue on a mobile device. The session cannot be paused and resumed, so finish it in one sitting. Success attaches Comment Code 356. A failed attempt produces Reject Code 74 with Comment Code 354; an abandoned one, Reject Code 74 with Comment Code 355. The highest-risk category is not offered the step and is rejected under Code 75 with Comment Code 357.
A rejected form is not the end of the road. Since 3 May 2026 aid offices have been able to clear the status by running the V4 identity procedure and then setting a field called "FAA Fraud Override" in the FAFSA Partner Portal, which generates a fresh transaction carrying an SAI and Pell eligibility, marked with Comment Code 358. Another school listed on your form may rely on that confirmation rather than repeat it — may, not must. A follow-up Q&A of 17 July 2026, APP-26-09, confirms that any of them can insist on running its own instead. Comment Code 360 means the screen could not run for technical reasons; nothing is being asked of you, and the record is scored again if you later submit a correction.
One line in that announcement explains a lot of late selection notices. The Department ran a one-time screen over 2026-27 forms already submitted before the April launch, warning that it would likely push additional records into V5 where fraud risk appeared. It did run, and APP-26-09 describes the forms it caught as carrying "both the V5 Verification flag and the 353 comment code." If you filed in winter and heard nothing until summer, that is a plausible reason.
What is frozen while you wait
Not everything, and not in the way people assume. Under 34 CFR 668.58, a school with no reason to believe your information is wrong may hold the money, or may make one disbursement from each of the Pell Grant and FSEOG programs for your first payment period. It may employ you under Federal Work-Study for the first 60 consecutive days after your enrollment. It may originate a Direct Subsidized Loan without disbursing it. The Handbook adds that a V1 student can be given Direct Unsubsidized and PLUS money before verification finishes, case by case and with documentation. V5 has no such room in it. Nothing moves.
Miss your school's deadline and section 668.60 takes over. Additional FSEOG stops and what you already received has to be repaid, Work-Study employment ends, and no further Direct Loan of any kind — subsidized, unsubsidized or PLUS — can be originated or disbursed. Subsidized loan money the school drew down but never paid out goes back. Miss the Department's outer deadline and the Pell Grant for that award year is forfeited, including money already paid to you. The separate question of when approved money actually lands is covered in entrance counseling, the MPN and when loan money arrives.
An oddity worth knowing if you read the regulation yourself: Subpart E still speaks of the Expected Family Contribution and still lists the Federal Perkins Loan among the subsidized programs. The form has produced a Student Aid Index since 2024-25. The regulatory text has not caught up, and that gap is not a sign you opened the wrong section.
Two dates, and the earlier one is probably your school's
Table A of the 2026-2027 award year deadline dates notice, published 22 June 2026 at 91 FR 37096, requires your institution to receive verification documents by the earlier of 120 days after your last date of enrollment for the award year, or 18 September 2027. The notice's own preamble carves out an exception to that row: students the Department placed in V4 or V5 are not on it. Their clock is the school's, the 60-day one described above.
The Handbook, written before that notice existed, could only say the date was expected to fall in mid-September 2027. When you find a deadline on someone else's page, it is worth working out which of the two they copied, because a campus that took the estimate rather than the notice is publishing a guess with a day attached to it.
Your own deadline is almost certainly earlier and is not optional. Section 668.53 requires every participating school to have written policies covering the time period for submitting documentation and the consequences of missing it, and to explain both to you clearly. Search your aid office's site for "verification policy" alongside the award year and read for two things: the date, and whether the office says it will still process late documents at its discretion. One more detail from the Handbook costs people entire files — signatures on worksheets and returns have to be collected at the time of verification. They cannot be added after the deadline has passed. A packet that arrives on time with a blank signature line is not a packet that arrived on time.
Frequently asked questions
Does being selected for verification mean the Department thinks I lied?
Not by itself. Selection is a flag on your ISIR, and applications get flagged for reasons that have nothing to do with dishonesty — manually entered income, an updated family size, a correction submitted after the fact, or a school choosing to verify an item on its own. What did change for 2026-27 is that a second, separate track now exists. Since 26 April 2026 the FAFSA form itself runs a real-time identity fraud screen, and an application rejected under that screen carries Reject Code 74 or 75 rather than a verification tracking group. That one is about identity, and your aid office can resolve it.
My school asked for an IRS tax return transcript. Is that still required?
Only for figures the exchange did not deliver. Dear Colleague Letter GEN-25-10 of 26 November 2025 tells institutions they are not required to collect a Tax Return Transcript or a signed copy of the 2024 income tax return if federal tax information was successfully transferred through FA-DDX and used in the Pell Grant eligibility determination and/or the Student Aid Index calculation. Manual entries are a different matter — returns filed with a U.S. territory or a foreign government, self-employment figures the exchange could not match, and foreign income exempt from federal taxation all still need paper. If a request looks broader than that, ask the office which specific item failed to transfer.
What is the deadline for sending verification documents for 2026-27?
Table A of the 2026-2027 award year deadline dates notice, published 22 June 2026 at 91 FR 37096, sets receipt of verification documents by the institution at the earlier of 120 days after your last date of enrollment for the award year, or 18 September 2027. Your school may set an earlier date and most do, but it cannot set a later one. Students the Department placed in Verification Tracking Group V4 or V5 are excepted from that row and sit on a different clock, and it is the school's to meet: identity results go to the Department no more than 60 days after its first request to you, with any later change to a result due within 30 days.
I rolled over a retirement account in 2024. Does that matter here?
It can, and it is the most expensive thing families miss in this process. A qualified rollover is not taxable income, but neither an IRS transcript nor the data transferred through FA-DDX identifies a distribution as a rollover, so it can sit in your file as untaxed income and push your Student Aid Index up. The 2026-2027 Application and Verification Guide is explicit that rollovers still have to be verified even when the underlying figure arrived as federal tax information. The fix is a signed, dated statement giving the rollover amount, or the word rollover written and signed beside the item on the return.