The state has described a transcript of evidence. Here is what one has to hold.

The state’s own words

The Department’s June 15, 2026 release says students “will demonstrate readiness through evidence of learning developed over time,” and that it “will establish statewide performance standards, common rubrics, quality assurance processes, and accountability measures,” and quotes Commissioner Betty A. Rosa on “demonstrated readiness rather than accumulated seat time” (the release; NYSSBA’s report of the meeting is at NYSSBA, June 29, 2026). New York Focus’s report of the meeting quotes Deputy Commissioner Angelique Johnson-Dingle on current transcripts, which do not “adequately reflect what a student knows and what they are able to do,” and says graduates would receive a “universal transcript or learner profile” that “would document alignment with state learning standards and the six attributes,” that “it’s unclear exactly what the transcript would look like,” and that the state is expected to “release them within the next year” (New York Focus, June 19, 2026). The phrase and the timeline are the report’s account of the deputy commissioner’s remarks; neither is in the Department’s release, and nothing on this page treats them as a Department commitment. The Department’s September 14, 2026 release adds that districts and schools “will develop local assessment strategies that draw on multiple sources of evidence, including classroom assessments, student work, performance-based learning experiences, educator observations, and State assessments” (the release).

The word the state uses, in every one of those texts, is evidence. Evidence raises three questions a course list never had to answer: who saw it, who can check it, and where the copy lives. A transcript that answers them is a transcript of evidence. One that does not is a list of course titles with a new heading.

Three properties a transcript of evidence needs

1. It is held by the student.

A transcript that lives only in a state system is a record of that system. The student changes schools, moves out of state, applies to an employer that will never log in to a New York portal, or comes back for the record after the system has been replaced, which it will be at least once between the first draft and the Class of 2033. Held means the student, through the family until majority, has the copy on a device of their own, can export it in open formats, can share a link and take it back, and keeps it when the issuer stops issuing. The state may hold a copy. It should not hold the only one.

2. Every entry names its witness, and says how far that witness’s identity was checked.

Evidence has to bottom out in a person. For a capstone, a defense, or a placement, the fact a reader needs is that a named adult who was there wrote down what they saw, on a date, and that the record states plainly what check was performed on that adult’s identity: an address, an institutional address, a document, a history. Where the witness disagrees with the school’s grade, the disagreement has to stay visible rather than be resolved by whoever holds the database.

3. It is verifiable with no login and no vendor.

A college in another state, an employer, a scholarship office: none of them will get an account on a state system to check one applicant. The transcript has to be checkable at one link with nothing to install, and checkable again with a published algorithm and no server at all, so that if the hosting system goes dark the record does not go with it.

How the open standard does each today

The specification is published at eformogi.com/spec in eleven chapters, licensed CC BY 4.0 so that any district, vendor, or state may implement it, with a reference verifier and twenty-four conformance vectors under Apache-2.0. What follows is where each property is stated, and what the reference implementation does about it now.

Held by the student. Chapter 01 makes the family the records office of record: the family issues, and the school, when there is one, is a witness or a declaring issuer named on the row. The family chooses the name that appears as issuer, may withdraw any receipt it issued (a withdrawn receipt is served as withdrawn, never as a dead link), and holds the record on the student’s device and in an encrypted cloud copy with an export in open formats. The founding issuer terms promise that if a school stops paying, its learners keep the record and its export. Chapter 04 states the honest limit in its own words: the family’s signing key is held in escrow by Eformogi today, and a page that says otherwise is not quoting the standard.

Every entry names its witness. Chapter 03 defines the attestation: the signer’s name, role, organization, a statement in their own words, the date, and for a course row the relationship and the grade attested, with the address kept only as a hash and nothing uploaded. A course row takes only an invited signature. Section 3.9 defines four identity levels, 0 to 3, and the sentence a reader sees for each: email address only; invited at a school or organization address and signed through the link sent there; identity checked against a document by staff, with only the record of the check kept; and established history, a count of prior co-signatures. The level is a fact about a check, never a comparison of one signer with another, and a disagreeing grade is rendered beside the family’s rather than hidden.

Verifiable with no login and no vendor. Chapter 06 is the verify page: one link, no account, and two paragraphs on every surface saying what was verified and what was not. Chapter 05 is the log: every public receipt is a leaf in an append-only Merkle log, a signed tree head is published daily and anchored in a third-party git history, and any receipt’s inclusion is provable offline against a head and the published organization key. The reference verifier is one Node file with no dependencies, no configuration, and no network access, packaged as @eformogi/verify-offline 0.1.0, and the organization key is published at eformogi.com/.well-known/did.json so a reader can pin it themselves. What the offline path cannot see today, the standard says out loud: a later withdrawal is visible only online.

Chapter 10 adds the rule about the name. The receipt a family issues is a Witness Transcript™, and an implementation whose records pass the conformance suite may call its own artifact that; one that has not passed may not, and nobody, including us, may describe an implementation as certified or official against the standard.

What a receiver sees at one link

How a state-hosted transcript and a student-held copy can coexist

Two chapters answer this, and neither depends on the state choosing us.

Chapter 08 makes a jurisdiction a plugin. A state’s graduation rule, a district’s quarterly report, a program’s form: each is a read of the same record through a lens, and a render of that read into the paper a particular office asks for. A lens is pure, cited, versioned, dated, and replaceable; it never alters the record and never appears on a verifiable receipt. Presence in the registry is earned by an issuer operating in that jurisdiction, who maintains the lens and owes its re-verification. So New York’s rubrics, when they are published, are a lens over evidence that already exists, and when the rubric changes between drafts the lens changes and the evidence does not.

Chapter 11 maps the record onto the formats a state system already reads. The chapter maps a transcript, a course row, and a witness attestation, field by field, onto the W3C Verifiable Credentials Data Model 2.0, Open Badges 3.0, and the Comprehensive Learner Record 2.0, and states what a bridge export would emit. The bridge is planned, not built, and the chapter says so. Its rules are the point for a state process: every exported credential must link the receipt it came from, by its verify URL, its receipt id and hash, and its proof URL, so a system that holds the state’s copy can always point back at the source; an export may carry no more than the public verify page shows unless the family adds more; and the facts the three standards have no slot for (how far a signer’s identity was checked, whether a witness disagreed, who holds the key) travel as prose, with the verify link as the place a reader goes to see them in the shape they were made.

Put together: the state hosts its transcript in whatever format it chooses and reads the student’s record through its own published lens; the student holds the source; the state’s copy carries the receipt ids and hashes of what it read; and a reader who wants to check does so at the link, or offline, without an account on either system. If the state’s system is replaced, the student’s copy and the anchored log outlive it. Interoperability is chapter 11 at eformogi.com/spec/interop; the plugin rule is chapter 08 at eformogi.com/spec/jurisdiction-plugins.

What this page does not claim

• The state has not adopted this standard and has not said it will. It has described what its transcript is for. This page checks three properties against that description and nothing more.
• A mapping is not a reader’s decision. Chapter 11 proves a field can be carried; it does not prove any receiver’s software will read it the way the record means it, and it says so.
• Nothing here is legal advice. How a public district contracts for a system that holds student records is a question for its counsel, and the agreement for a public agency is drafted with ours.

Frequently asked questions

The state is a plugin, not the identity

A universal transcript is a fine idea, and the plan of record here is built on one: a learner record on an open standard, issued by the schools and counselors who already hold the learners, in which the state is a lens and never the identity. The learner holds the record. The adults who were there sign it. Anyone checks it at one link. A state that builds its transcript on those three properties, in any format and on any system, has built something the student keeps, and that is the whole of what this page asks. The promises behind it are written down in the sovereignty contract.

See also: what the Regents change requires · documenting Portrait evidence · the interoperability chapter · the reference verifier