By Alicia Ward, John Graff June 23, 2025
Hazing, which can cause serious harm, including injury, death, and long-term emotional or psychological
trauma, continues to persist on campuses despite state level anti-hazing laws and campus initiatives aimed
at educating students, faculty, and staff about resulting dangers and consequences. On December 23,
2024, the Stop Campus Hazing Act (SCHA) was signed into law bringing significant changes to the newly
renamed Jeanne Clery Campus Safety Act (the “Clery Act”) intended to enhance campus safety and prevent
hazing. These changes include new requirements regarding hazing prevention, data reporting, and
creation of new policy. The following is a high-level summary of what institutions need to know about the
SCHA’s new requirements and corresponding impacts to existing Clery Act compliance.
1. New Definitions
The SCHA adds two definitions to the Clery Act:
(1) The term “hazing,” for purposes of reporting statistics on hazing incidents, means 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—(a) is committed in the course of an initiation into, an affiliation with,
or the maintenance of membership in, a student organization; and (b) causes or creates a risk,
above the reasonable risk encountered in the course of participation in the institution of higher
education or the organization (such as the physical preparation necessary for participation in an
athletic team), of physical or psychological injury.¹
(2) The term “student organization” . . . means an organization at an institution of higher education
(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 students
enrolled at the institution of higher education, whether or not the organization is established or
recognized by the institution.²
2. The Annual Security Report Will Now Include Hazing Policy Statements and Statistics
Beginning January 1, 2025, institutions are required to collect information about hazing incidents to
include in the Annual Security Report (ASR) (the October 1, 2026 ASR). For purposes of ASR compliance,
institutions must apply the SCHA’s definition of hazing (rather than the institution’s policy definition of
hazing, if different) to incidents involving student organizations (both recognized and unrecognized) that
occur on Clery geography (i.e., on-campus, non-campus, and public property).
3. New Policy Obligations Imposed with a June 23, 2025 Compliance Deadline
Clery mandates that institution ASRs contain various policy statements regarding campus safety protections, including: external campus security, internal building security (including in residence halls), contact
information for crime reporting, institution relationships with external law enforcement, legal authority for
powers exercised by campus law enforcement, missing persons investigations, campus emergency preparedness and response policies, timely warnings and emergency notifications, preparation of crime statistics
for inclusion in the ASR, fire safety rules and data concerning fires on campus,³ and sexual misconduct response procedures and grievance policies.
The SCHA adds two new policy disclosure requirements:
(1) Anti-Hazing Policy: Institutions must establish a statement of current policies relating to hazing
as defined by the institution (if different from Clery’s definition). This policy statement must include
the following information: (a) how to report incidents of hazing; (b) the process used to investigate
incidents of hazing; and (c) information about applicable local/state/Tribal laws governing hazing
(as defined by such local, State, and Tribal laws).⁴
(2) Hazing Prevention and Awareness Programs: Institutions must create and maintain a statement of policy regarding prevention and awareness programs related to hazing (as defined by the
institution, if different from Clery’s definition) that includes a description of research-informed campus-wide prevention programs designed to reach students, staff, and faculty. This policy statement
must include primary prevention strategies intended to stop hazing before hazing occurs.⁵
Institutions with existing anti-hazing policies and/or prevention and awareness programs should evaluate
their policies and programs to ensure that they align with the requirements of the SCHA.
Institutions without anti-hazing policies and/or prevention and awareness programs should take steps to
adopt and implement SCHA-compliant policies and programs along with the required policy statements for
inclusion in the ASR.
4. Campus Hazing Transparency Report (CHTR)
Beginning July 1, 2025, institutions must collect hazing-related data, and by December 23, 2025, make
that data available to the public in a transparent manner, not only as part of the ASR but also in standalone
reports on hazing prevention efforts and related statistics that are developed in accordance with the statement of policies referenced above. At least biannually, institutions must update the CHTR.⁶
The CHTR must summarize findings concerning any hazing violations (the institution’s definition of hazing
applies rather than the SCHA definition, if different) and is only applicable to organizations established or
recognized by the institution. For purposes of CHTR compliance, reporting is not limited to “campus” (i.e.,
Clery geography definitions are not applicable to this obligation).
The CHTR must capture the following information:
• Name of student organization (recognized student organizations only);
• A general description of the violation that resulted in a finding of responsibility;
• 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
(if applicable);
• Date on which the incident was alleged to have occurred;
• Date on which the investigation into the incident was initiated;
• Date on which the investigation ended with a finding that a hazing violation occurred; and
• Date on which the institution provided notice to the student organization that the incident resulted in a
hazing violation.
The CHTR may (but is not required to) include the following information:
• Additional information as determined by the institution to be necessary; and
• Additional information that must be reported pursuant to applicable state law.
The CHTR must not include personally identifiable information in accordance with the Family Educational
Rights and Privacy Act.
The CHTR must be published in a prominent location on the institution’s website along with:
• A statement notifying the public of the availability of hazing statistics, including a link to the ASR;
• Information about the institution’s policies related to hazing and applicable local, state, and Tribal laws
on hazing; and
• Information required for the CHTR.
5. SCHA: Compliance Snapshot
(1) Summary of Compliance Deadlines – Mark Your Calendars:
(2) ASR Versus CHTR:
6. Next Steps for Institutions
(1) Data Collection: Collect hazing data regarding incidents reported to CSAs and local police.
(2) Plan Ahead: Develop a road map to determine required next steps to meet the various compliance
obligations and deadlines.
(3) Review and Revise Policies and Protocols:
(4) Incident Tracking and Classification: Enhance tracking systems (Clery compliance software, reporting templates, spreadsheets, etc.) to record hazing incidents per Clery Act definitions and support accurate reporting of hazing data in the ASR.
(5) CHTR: Prepare and publish a CHTR that meets all statutory requirements:
(6) Educate and Train:
(7) Reporting Mechanisms:
(8) Communication and Transparency:
It remains to be seen what the U.S. Department of Education’s enforcement of the Clery Act will look like
under its new administration. Notwithstanding, institutions should take steps to align with the ongoing
and new requirements of the Clery Act to strengthen compliance. Note that the Department of Education
has increased the civil monetary penalty from $69,733 to $71,545 for each violation of the Clery Act. This
adjustment became effective January 21, 2025 and applies to “civil penalties assessed after January 21,
2025, whose associated violations occurred after November 2, 2015.”
If you have any questions about the impact of the SCHA or need assistance with updating your institution’s
policies and reports, please contact:
• Alicia Ward (award@hrwlawyers.com / 617-348-4357); or
• John Graff (jgraff@hrwlawyers.com / 617-348-4356).
¹ See 20 U.S.C. § 1092(f)(6)(A)(vi). This definition also includes a detailed list of examples that constitute hazing. Id.
² See 20 U.S.C. § 1092(f)(6)(A)(vii).
³ Clery also requires certain fire safety statistics and policy disclosures, which may be published either in a standalone fire safety report or consolidated into an institution’s ASR. These fire safety disclosures apply only to institutions with on-campus student housing facilities
and focus exclusively on those facilities.
⁴ See 20 U.S.C. § 1092(f)(1)(K).
⁵ See 20 U.S.C. § 1092(f)(1)(L).
⁶ Notwithstanding the December 23, 2025 deadline, institutions are not required to publish a CHTR until a recognized student organization is found to have violated institutional hazing policy. Additionally, the SCHA does not require institutions to update the CHTR for any period in which there are no findings of a hazing violation for such period. See 20 U.S.C. § 1092(f)(9).
