The 2026 FCRA refresh — what hiring teams need to do by Q3

On March 14, 2026, the CFPB published its long-awaited refresh to the Fair Credit Reporting Act compliance bulletin. For hiring teams, three changes matter immediately — and they all have a Q3 enforcement runway.

1. Pre-adverse action timing is now explicit

The old guidance said employers must give candidates a 'reasonable' window between the pre-adverse action notice and the final decision. The new bulletin defines reasonable as a minimum of seven business days, with a hard floor of five for time-sensitive roles. If your ATS auto-advances candidates faster than this, you're now out of compliance.

2. AI-assisted adjudication must be disclosed

Any system that scores, ranks, or recommends an adjudication outcome must be disclosed to the candidate at the point of consent. The disclosure has to name the categories of data the model uses and offer a human-review path. Ethur's adjudication module ships with a templated disclosure that meets the new requirement out of the box.

3. Dispute windows extend to 45 days

Candidates now have 45 days (up from 30) to dispute information in a consumer report. Reinvestigation timelines compress accordingly — you have 30 days to complete the reinvestigation, with a 15-day extension only if the candidate provides new information.

What we're doing for customers

• Updated all consent and disclosure templates with the new AI language.
• Added a configurable pre-adverse action timer with safe defaults.
• Extended the dispute portal to support the new 45-day window with audit trails.
• Published a free compliance checklist (link in our Guides section).

If you remember one thing: audit your auto-advance rules before July. That's where most teams will fail their first 2026 audit.

Questions? Our compliance team runs office hours every other Thursday — book a slot from your dashboard.