There are different regulatory and legal requirements for each country so it has to be looked at and evaluated country by country - items to be evaluated include (but are not limited to) accreditation, access into your systems/use of VPN in the country, creation of permanent establishment in a country, DST/GST taxes, return and other filing requirements. We know from evaluating that certain countries do not recognize online programs and others it may depend on the amount of live interaction versus recorded. Definitely have legal counsel involved as well as budgeting, provost, tax to make sure all areas are covered.
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Susan Clark
Sr Director of Tax
Emory University
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Original Message:
Sent: 02-13-2026 01:56 PM
From: Kevin Doyle
Subject: Online education to students in other countries
Hello NACUBO community:
First post here.
Hoping to learn of any regulatory or legal requirements institutions should follow to ensure that allowing students in other countries to take advantage of in a U.S. based online degree program. We have not been allowing this, but it is unclear if there are any real reasons not to do so. This may be somewhat country-specific, I understand. Are some countries clearly lower risk? Have other schools notified or sought permission from the other country? Or perhaps notified the students that the degree may or may note hold value in their home country? Looking for advice on how best to proceed.
Best regards,
Kevin Doyle
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Kevin Doyle
President & CEO
Hazelden Betty Ford Graduate School
kdoyle@hazeldenbettyford.edu
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