The Justice Department and the Education Department announced a settlement Oct. 19 with the University of North Carolina at Chapel Hill that closes 18 federal civil rights investigations and keeps the school eligible for federal funding. In return, UNC agreed to race-blind admissions and new rules on antisemitism, running through Dec. 31, 2028.
The Justice Department’s release says the agreement resolves investigations under Title VI of the Civil Rights Act of 1964. The agreement itself says UNC denies liability for the matters under investigation and that the document is not an admission by either side.
What the Agreement Requires on Antisemitism
UNC must create a Title VI Coordinator in its University Compliance Office with enough authority to do the job. The university must keep policies against discriminatory harassment, make sure Jewish and Israeli students are covered by its Non-Discrimination Policy and promptly assess complaints, investigating where warranted. Every student, faculty member and staff member must take antisemitism training, and staff who review complaints get expert training.
The agreement also covers campus policing and protest rules. UNC must put additional law enforcement in place when warranted and train its police on prohibited antisemitism. It must ban face masks that conceal identity, with exceptions for verifiable religious or medical needs and for occasions such as Halloween, and people must show identification when authorized officials ask. Student groups that engage in antisemitic discriminatory conduct can be defunded, suspended or de-recognized.
What Changes for Admissions and Scholarships
The admissions section requires what the agreement calls a color-blind system. UNC may not give preferences by race, color or national origin, including through diversity considerations. It may not analyze racial data to change the makeup of the student body and may not use what the agreement calls racial proxies, meaning other applicant traits used to affect racial diversity because they are thought to correlate with race.
The agreement still allows admissions staff to consider how applicants overcame personal adversity and their family background, such as poverty, as long as those factors are not used to favor applicants by protected characteristic. UNC must take reasonable steps to keep reviewers from knowing an applicant’s race.
It may not disfavor applicants who decline to state it. It must use standardized test scores when submitted, consistent with the UNC System minimum eligibility policy. It also may not consider protected characteristics in recruitment, including through bridge or pipeline programs, or in choosing admissions personnel.
The rules extend past admissions. UNC must apply standards consistent with the Supreme Court’s 2023 decision in Students for Fair Admissions v. Harvard to scholarships, financial aid and programming. Scholarship criteria cannot use diversity or underrepresented status as a stand-in for a protected characteristic.
Affinity groups, centers, graduation ceremonies and honors programs may not segregate or discriminate, and UNC may not run programs that promote race-based outcomes, quotas or diversity targets. A separate section bars the university from favoring foreign students over U.S. citizens based on a protected characteristic or citizenship.
How Federal Officials Will Watch Compliance
Chancellor Lee H. Roberts must pick a Merit & Civil Rights Administrator within 30 days of the agreement taking effect. The administrator reports to the chancellor and quarterly to the assistant attorney general. The chancellor may remove the administrator only for good and reasonable cause with the assistant attorney general’s approval, and the Justice Department can demand removal if it finds performance inadequate.
The first report is due within 90 days. It must cover every complaint of race, color, national origin or Jewish or Israeli ancestry discrimination or harassment received from Oct. 7, 2023, through the effective date, with UNC’s response to each. That look-back is about three years, a calculation from the agreement’s dates. Reports then arrive quarterly, and the chancellor must certify each one under penalty of perjury. Failing to certify counts as a material breach.
If the government decides UNC is in substantial noncompliance, UNC gets 15 business days to cure or propose a fix, and the government has 10 business days to accept or reject it in writing. A 60-day mediation follows, with UNC paying the costs. If talks fail, the government decides on impasse and material breach in its sole discretion. Either side may then sue in the U.S. District Court for the Middle District of North Carolina. UNC gives up statute of limitations and Administrative Procedure Act timeliness defenses for any Justice Department enforcement action.
What UNC Gets in Return
Under the agreement, the Education Department’s Office for Civil Rights closes 18 listed investigations, and the Civil Rights Division closes a compliance review it opened April 18, 2025, both without an adverse finding. That review had been open about 18 months when the settlement was announced, by the same arithmetic. Other investigations, grant terminations and fines that predate the agreement are held in abeyance. If the government finds UNC kept its commitments, those matters close on the termination date.
UNC stays eligible for grants and awards in the ordinary course while the agreement holds. Measured from the Oct. 19 announcement, the term lasts about 26 months. The agreement sets the effective date at the last signature, and the release does not give a dollar figure for any payment.
Harmeet K. Dhillon, assistant attorney general for the Civil Rights Division, is quoted in the release saying the goal is that “all students regardless of their ancestry or race receive equal treatment under the law.” She also said she hopes other institutions will follow.
Kimberly Richey, the Education Department’s assistant secretary for civil rights, said applicants will now be judged on merit. The release contains no separate statement from UNC. The agreement carries the university’s denial of liability and the signature of Chancellor Roberts.
Why the Document Matters Beyond Chapel Hill
The agreement says UNC must follow the department’s July 29, 2025, guidance for federal funding recipients on unlawful discrimination for as long as it stays in force and is consistent with court decisions. UNC also agreed not to challenge it. The agreement contains an academic freedom clause saying the government does not intend to dictate academic speech or curricula. Only the two parties can enforce the agreement, and non-parties get no private right of action. The Civil Rights Division says it will keep monitoring colleges for Title VI compliance, and it invites the public to file complaints at civilrights.justice.gov.
