Project 2025's Attack on Title IX and Civil Rights Data Collection Endangers Students

Project 2025's blueprint for the Department of Education targets five Biden-era regulatory changes, with a particular focus on Title IX and the Civil Rights Data Collection (CRDC). The playbook demands that the next administration rescind Title IX rules that protect transgender students, define 'sex' as biological sex at birth, and eliminate the nonbinary sex category in CRDC—a move that would erase the existence of nonbinary students from federal data. The same section also calls for repealing borrower-defense and public-service loan-forgiveness regulations, gutting charter-school accountability, and undermining special-education equity rules. The stated goal is to 'restore the rights of women and girls' and 'protect due process,' but the actual effect is to strip protections from vulnerable students and to make discrimination legally permissible.

As of early February 2025, the Trump administration has executed two key recommendations: on January 20, it signed an executive order to define 'sex' in federal law as biological sex at birth, and on January 30, it directed agencies to rescind Biden-era Title IX rules. However, the full suite of Title IX rule changes called for in Project 2025—including the restoration of the 2020 DeVos regulations—has not yet been implemented through formal agency rulemaking. The elimination of the nonbinary sex category from the CRDC has not been confirmed by any February 2025 action; the available news reports cover only Title IX executive orders, not OCR data collection changes. The borrower-defense and charter-school program rescissions also remain unexecuted as of this writing. This partial execution means the fight is ongoing: students and advocates still have a window to block the most extreme rollbacks through lawsuits, congressional oversight, and public pressure.

Every one of these rollbacks would cause real harm—not just to transgender and nonbinary students, but to all students who rely on federal data for safety and accountability. Erasing nonbinary students from CRDC means schools are not required to report bullying, harassment, or exclusion based on gender identity, masking the true scope of discrimination. Gutting Title IX protections leaves transgender students vulnerable to being barred from restrooms, locker rooms, and sports, and to being misgendered or outed against their will—actions that can lead to depression, self-harm, and even suicide. Weakening borrower-defense rules leaves students who were defrauded by for-profit colleges with no recourse. And rolling back charter-school oversight allows poorly performing charters to waste public money without accountability. This is not about 'restoring rights'—it is about dismantling the federal role in protecting children from discrimination, debt, and educational failure.

A real alternative exists: Congress should codify Title IX protections for sexual orientation and gender identity, as the Equality Act proposes. The Department of Education should strengthen CRDC to include nonbinary data and increase enforcement of existing anti-discrimination laws. Borrower-defense rules should be expanded, not repealed. And charter schools should be held to the same accountability and transparency standards as traditional public schools. The goal must be an education system that protects every student—regardless of gender identity, race, disability, or income—rather than one that picks winners and losers based on political ideology.