Why Does the FAFSA Collect the Student's ITIN If the Social Security Number Is Not Provided?

The following is preliminary guidance received by NASFAA from the U.S. Department of Education (ED) and it is subject to change as ED finalizes the 2024-25 FAFSA.

The 2024-25 FAFSA includes data fields to collect Individual Taxpayer Identification Numbers (ITINs) for the student applicant and contributors; however that field will very rarely display for the student.

A Social Security Number (SSN) is required for the student to establish Title IV aid eligibility under 34 CFR 668.32(a)(i), so the SSN must be reported on the FAFSA if they have one. Note that students who are residents of the Freely Associated States (Marshall Islands, Micronesia, and Palau) apply initially without an SSN until ED assigns them a nine-digit pseudo-SSN. Students who are not residents of the Freely Associated States will not be allowed to submit the online FAFSA for processing without their SSN.

The ITIN is used to access income and tax data retrieved directly by ED from the IRS in the absence of an individual’s SSN. ED expects to be collecting ITINs primarily for parents and spouses since there is no requirement for them to have an SSN.

According to ED, the ITIN field was added in the student section of the FAFSA in case it is needed by ED for processing; however, ED anticipates it will rarely display for a student completing their own portion of the online FAFSA because the ITIN field will display only when the SSN field is blank. On the paper FAFSA, applicants are instructed to provide the ITIN only in the absence of an SSN. An online applicant who leaves the SSN field blank is asked next about their state of legal residence to help identify students who need to be assigned a pseudo-SSN.

Students who are residents of the Freely Associated States: Students who have already been assigned a pseudo-SSN will know to enter that number in the SSN field. If applying online, the ITIN field will not display for these applicants and they will submit the FAFSA as usual. If using the paper FAFSA, the instructions indicate they may enter an ITIN. New applicants who need a pseudo-SSN may leave the ITIN field blank because it is not a required field for any individual. Whether they provide an ITIN or not, as long as they correctly indicate their state of legal residence, new applicants will be able to submit the FAFSA for processing and be assigned a pseudo-SSN.

Student who are NOT residents of the Freely Associated States: For online and paper FAFSAs, if the student’s SSN field is blank—even if they provided an ITIN instead—the FAFSA will not be processed due to the required database matches for Title IV aid eligibility. According to ED, online applicants will not be able to submit their FAFSA, and paper FAFSAs will be rejected, if there is no SSN and the student did not identify as a resident of the Freely Associated States. The ISIR should include all relevant data to allow the school to assist the student.

For more information regarding applicants who are residents of the Freely Associated States, refer to AskRegs Knowledgebase Q&A, Does a Student From the Marshall Islands, Micronesia, Or Palau Complete the FAFSA Using Their ED-Assigned Or Actual Social Security Number?