Anti-Hazing Efforts Required for Academic Year 2025-26

07.23.2025

The 2025-26 academic year brings with it a renewed focus on anti-hazing efforts, including a new California law that permits students who are injured by hazing to recover civil damages from public and private institutions of higher education (“Institutions”), including community college districts (“CCDs”), unless the Institution has taken certain preventative actions. This Alert follows our previous Alert summarizing the federal Stop Campus Hazing Act[1] and California’s 2024 Assembly Bill 2193. This Alert provides further guidance for establishing compliant anti-hazing policies and procedures, as well as a comprehensive hazing prevention program.

Important Timelines

Under the federal Stop Campus Hazing Act, which is applicable to Institutions that receive federal funding, Institutions must take, or have taken, the following actions:

• Beginning January 1, 2025, Institutions must collect statistics on reported hazing incidents to be included in the Institution’s Annual Security Report (“ASR”). To be counted in the ASR, these incidents do not need to constitute a crime and need only meet the definition of “hazing” as set forth in the statute.[2] Whether the organization is officially recognized by the Institution is immaterial; all hazing incidents occurring in “Clery geography”[3] must be included.
• By June 23, 2025, Institutions must develop policies relating to hazing, including how to report incidents of hazing, the process used to investigate incidents of hazing, and information on applicable local, State, and Tribal laws on hazing. Also required is a statement of policy regarding prevention and awareness programs, i.e., a description of research-informed campus-wide prevention programs designed to reach students, staff, and faculty. If your CCD/Institution has not yet adopted a policy and implemented a comprehensive prevention program, we recommend that it do so as soon as possible.
• By July 1, 2025, Institutions must begin tracking findings concerning any student organization established or recognized by the Institution that is found to be in violation of the Institution’s standards of conduct relating to hazing.
• By December 23, 2025, Institutions must make a Campus Hazing Transparency Report publicly available on its public website if a finding has been made that an established or registered student organization violated the Institution’s standards of conduct relating to hazing. The Report must be updated not less than two times per year, if additional violations have been found, and must not contain any personally identifiable information. 
• By October 1, 2026, the Institution’s ASR must include the hazing incident statistics collected in calendar year 2025.

California’s Assembly Bill 2193, which adds Section 66305 et seq. to the Education Code, subjects an Institution to potential liability for hazing incidents occurring on or after January 1, 2026. As of that date, a former, current, or prospective student, against whom hazing is directed by an affiliated organization (on or after January 1, 2026) and who has suffered injury as a result, may commence a civil action for damages against the Institution, if the Institution knew or should have known of the hazing practice and failed to take reasonable steps to prevent it. To defend against such claims, Institutions must have enacted rules and regulations governing student behavior that prohibit hazing, allow for anonymous reporting of hazing incidents, and provide for disciplinary actions for the violation of hazing prohibitions. Such rules and regulations must govern employee behavior, as well. In addition, Institutions must have enacted procedures by which all employees are informed of the rules and regulations and must have implemented a “comprehensive prevention and outreach program” addressing hazing.

A “comprehensive prevention and outreach program” must include the following, at a minimum:

• Hazing awareness, prevention, and the Institution’s anti-hazing policy;
• Campus policies and resources relating to hazing, including how to report hazing to the appropriate campus personnel, which includes anonymous reporting; and
• A focus on prevention and bystander intervention training as it relates to hazing.

The prevention and outreach program must be included as part of every incoming student’s orientation and presented annually to athletic teams and affiliated sororities and fraternities.

Institutions that need assistance developing a comprehensive anti-hazing prevention and outreach program may want to explore the resources available through the third party vendors.

Assembly Bill 2193 also requires the California State University, the University of California, and independent institutions of higher education to report the number of hazing incidents to the California Legislature annually, beginning on or before June 30, 2026.

A Note Regarding Hazing Investigations

Hazing allegations may implicate other laws and policies, including Title IX (sexual harassment, sexual assault, dating violence, domestic violence, and stalking) and Title VI (discrimination/harassment based on race, color, or national origin, including shared ancestry or ethnic characteristics). In such cases, Institutions will need to ensure the hazing investigation complies both with anti-hazing policies and procedures and with other applicable policies and procedures. This means that various campus offices will need to coordinate and, if necessary, consult with counsel for procedural advice. In certain instances, an Institution may be better served by using an external, rather than internal, investigator. It may be helpful for the assigned investigator to have specialized training in conducting hazing investigations.

For further information on the content of this Alert or related questions, please contact your AALRR attorney or the authors.

Special thanks to our law clerk, Camille Schaefer, for her assistance with this Alert.

[1] The Stop Campus Hazing Act amends the Clery Act, 20 U.S.C. 1092(f).

[2] This definition is set forth in the previous Alert.

[3] “Clery geography” includes (A) Buildings and property that are part of the institution's campus; (B) The institution's noncampus buildings and property; and (C) Public property within or immediately adjacent to and accessible from the campus.

This AALRR publication is intended for informational purposes only and should not be relied upon in reaching a conclusion in a particular area of law. Applicability of the legal principles discussed may differ substantially in individual situations. Receipt of this or any other AALRR publication does not create an attorney-client relationship. The Firm is not responsible for inadvertent errors that may occur in the publishing process.

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