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Key Facts
- Federal level: 34 CFR 668.41(d)(5) requires institutions to disclose the placement and types of employment obtained by graduates and identifies permitted sources for that placement and employment information.
- Federal level: 34 CFR 668.45 requires institutions to prepare completion or graduation rates annually and make them available no later than the July 1 after the covered period.
- Federal level: 34 CFR 668.44 requires institutions to designate an employee or group available on a full-time basis to assist with required disclosure information.
- National overview: ABA Standard 509 requires information a law school reports, publicizes, or distributes to be complete, accurate, and not misleading to a reasonable law school student or applicant.
- National overview: ABA Standard 509 includes employment outcomes and bar passage data as consumer information categories.
- National overview: ABA Rule 16 sanctions can apply for providing incomplete, inaccurate, or misleading consumer information that violates Standard 509.
- State level: ABA materials describe that almost all states rely exclusively on ABA approval for whether legal education requirements for bar admission are satisfied, with a small number adding requirements beyond ABA approval.
Last reviewed: May 2026. Legal rules, forms, deadlines, and procedures can change by jurisdiction, agency, and court system.
- Why law school disclosure rules emphasize complete, accurate, and not misleading information
- The ABA accuracy rule in Standard 509(a)
- Employment outcomes and bar passage data under Standard 509(b)
- How ABA Rule 16 handles misleading consumer information
- Accreditation background in the ABA standards preface
- Federal employment and placement disclosures under 34 CFR 668.41(d)(5)
- Federal completion or graduation rate timing under 34 CFR 668.45
- Federal disclosure support under 34 CFR 668.44
- Where the ABA and federal rules overlap on outcomes data
- Where state bar admission relies on ABA approval
- Related law school policy coverage on TheFirstFile
- Sources
Why law school disclosure rules emphasize complete, accurate, and not misleading information
ABA Standard 509(a) requires that all information a law school reports, publicizes, or distributes be “complete, accurate and not misleading to a reasonable law school student or applicant” (ABA Standard 509 and Rule 16).
The ABA accuracy rule in Standard 509(a)
Standard 509(a) sets a general consumer-information accuracy rule for law school disclosures, using three tied requirements: information must be complete, accurate, and not misleading to a reasonable law school student or applicant.
Employment outcomes and bar passage data under Standard 509(b)
ABA Standard 509(b) identifies specific categories of consumer information that include “employment outcomes; and bar passage data” (ABA Standard 509 and Rule 16).
How ABA Rule 16 handles misleading consumer information
ABA Rule 16 links the Standard 509 accuracy requirement to potential sanctions, stating that sanctions may be imposed for “Provision of incomplete, inaccurate or misleading consumer information in violation of Standard 509” (ABA Standard 509 and Rule 16).
Accreditation background in the ABA standards preface
The ABA standards preface states that, since 1952, the Council of the Section of Legal Education and Admissions to the Bar “has been approved by the United States Department of Education as the recognized national agency for the accreditation of programs leading to the J.D. degree” (ABA Section Council approval and bar admission reliance).
Federal employment and placement disclosures under 34 CFR 668.41(d)(5)
Federal student consumer-information regulations require disclosure of “the placement of, and types of employment obtained by, graduates of the institution’s degree or certificate programs” (34 CFR 668.41(d)(5) placement and types of employment).
What sources can schools use for placement data under 34 CFR 668.41(d)(5)
The same rule identifies categories of sources that can be used to support placement and employment information, including “State data systems,” “Alumni or student satisfaction surveys,” and “Other relevant sources” (34 CFR 668.41(d)(5) placement and types of employment).
Federal completion or graduation rate timing under 34 CFR 668.45
Federal rules require institutions to prepare completion or graduation rate information annually and require that it be made available “no later than the July 1” immediately following the specified period (34 CFR 668.45 completion or graduation rates).
Federal disclosure support under 34 CFR 668.44
Federal rules also require administrative support for disclosures, stating that each institution “shall designate an employee or group of employees” available on a full-time basis to assist in obtaining the information specified in related disclosure sections, including completion or graduation rate reporting and other required student-consumer information sections (34 CFR 668.44 employee availability).
Where the ABA and federal rules overlap on outcomes data
Both frameworks address outcomes-related information, but they do so through different structures:
- ABA Standard 509 identifies consumer-information categories like employment outcomes and bar passage data and pairs the accuracy obligation with Rule 16 sanctions.
- Federal 34 CFR 668.41 requires placement and types of employment disclosures using specified source categories, and federal 34 CFR 668.45 sets annual completion or graduation rate preparation and a July 1 make-available deadline.
- Federal 34 CFR 668.44 requires a designated full-time staff contact to support obtaining required disclosure information.
| Authority source | What it targets in the rule text | Outcomes examples mentioned in the rules | Timing or accountability elements |
|---|---|---|---|
| ABA Standard 509 and Rule 16 | Consumer-information accuracy for what a law school reports, publicizes, or distributes | “employment outcomes; and bar passage data” | Rule 16 allows sanctions for incomplete, inaccurate, or misleading consumer information in violation of Standard 509 |
| 34 CFR 668.41(d)(5) | Required disclosures on graduate outcomes | Placement and types of employment | Uses permitted source categories for the placement and employment information |
| 34 CFR 668.45 | Completion or graduation rate reporting | Completion or graduation rates | Make available “no later than the July 1” following the specified period |
| 34 CFR 668.44 | Institutional support for required disclosures | Disclosure information gathering support | Requires designation of an employee or group available on a full-time basis |
Where state bar admission relies on ABA approval
The ABA standards preface states that “Almost all rely exclusively on ABA approval of a law school” for satisfying a jurisdiction’s legal education requirement for bar admission, while “a small number of states have now added requirements” beyond ABA approval (ABA Section Council approval and bar admission reliance). It also states that “In all states, graduation from an ABA-approved law school is sufficient,” subject to additional requirements in that small number of states (ABA Section Council approval and bar admission reliance).
Related law school policy coverage on TheFirstFile
For another Archives > News & Cases item about ABA-related law school policy discussions, see ABA updates on law school admissions testing accommodations.
