On August 26, 2025, New York Governor Kathy Hochul signed into law Senate Bill S4559B / Assembly Bill A5448B. This landmark legislation makes New York the first state to require all colleges and universities, both public and private, to designate a Title VI Coordinator and comply with new annual notification, training, and recordkeeping obligations related to race, color, and national origin discrimination, including antisemitism and bias based on shared ancestry. Remember, the relevant federal law – Title VI of the Civil Rights Act of 1964 – does not require a Title VI Coordinator.

The NY law applies to all institutions of higher education covered by Article 129-A, which includes over 200 campuses such as SUNY, CUNY, and other regents-chartered colleges and universities. The law requires each institution to appoint a Title VI Coordinator within 90 days and requires annual training for all students and employees beginning in the 2026-2027 academic year.

Under the law, a university’s Title VI Coordinator will serve as the central point of contact for the university’s Title VI compliance and institutions have flexibility in structuring the position. As a result, the Title VI Coordinator may hold other duties and can appoint designees, but retains ultimate responsibility for compliance. When a complaint of discrimination or harassment based on race, color, or national origin is received, the Title VI Coordinator must offer supportive measures to the complainant, notify them of the institution’s policies and procedures, and ensure a robust process for investigating and resolving such complaints. As a result, the role of the New York-law required VI Coordinator looks very much like the Title IX Coordinator required by federal law – and the responsibilities and designations could very easily be held by the same employee.

The law also requires institutions to notify all students and employees each academic year about their nondiscrimination policy statement, reporting procedures, and the Title VI Coordinator’s contact information. Title VI Coordinators themselves must receive specialized training on their responsibilities under both federal law and New York state law.

This new law signals a shift in how all colleges and universities should be thinking about their Title VI compliance.

• For New York institutions of higher education, the law sets out specific proactive structures – dedicated coordinators, annual training, and transparent reporting – to ensure compliance under the federal Titel VI law.
  
  Colleges and universities should work with their legal counsel to review their existing policies and procedures for Title VI compliance gaps and revise as necessary, designate and train their Title VI Coordinator, update annual notification processes, plan for annual training, and establish robust recordkeeping systems.

• For institutions of higher education in other states, this law serves as a reminder of the importance of responding to complaints of discrimination and harassment based on race, color, and national origin, including shared ancestry.
  
  Colleges and universities in other states may decide to view the obligations under New York’s law as a model and considering voluntary adoption of similar roles and processes to strengthen their Title VI compliance and best practices.

For advice on your institution’s compliance with New York law and Title VI, structuring the Title VI Coordinator role, or developing training programs, please contact your Hunton lawyer.