A New York high school junior sitting down this winter to plan senior year faces a question no counselor in the state can fully answer: what, exactly, will it take to graduate in June 2028? The Class of 2028 is the first group of students who will not need to pass Regents exams to earn a diploma, and the rule that replaces that requirement has not yet been written.

That is not an exaggeration of the timeline, which comes from the State Education Department itself. The Board of Regents voted on Sept. 14 to direct staff toward sunsetting diploma assessment requirements and moving to a single diploma, with proposed amendments to Part 100.5 due before the board by February 2027 and implementation in the 2027-28 school year. Chalkbeat New York has reported that a final vote could come in June 2027, which would put the governing rule on the books a few weeks before the Class of 2028 starts its last year.

The direction makes sense, and educators have advocated for it for years. What does not make sense is the sequence. Before asking even one junior to plan around local assessment requirements, New York should publish the minimum standards, and do so this school year rather than through a regulation that arrives after the planning is done.

What Juniors Have Been Told So Far

The clearest explanation students have received came from New York City, the state's largest school district. Katie Hansen, the city Education Department's executive director of academic policy and systems, said in September that next year's seniors would graduate by completing their 44 required credits, and that "there won't be a separate system of assessments that students have to complete to meet graduation requirements." The city puts roughly 212,000 students in grades 9 through 11 under that guidance, according to Chalkbeat's reporting.

Hansen was also candid about what will not exist in time. "We're not expected next year to stand up a one-for-one replacement for the Regents exams," she said. JP O'Hare, a spokesperson for the State Education Department, described a phased transition in which current standards, credit requirements, local assessments and accountability remain in place while districts build something new.

Outside the city, the instruction to districts has been to begin experimenting. State materials describe local assessment strategies drawing on multiple sources of evidence, including classroom assessments, student work, performance-based learning experiences, educator observations and state assessments, and the department has released an initial template, guidance and a webinar. Zachary Warner, the state's assistant commissioner for state assessment, used a February webinar to warn districts against "waiting to start until we have everything perfectly in place."

Warner offers sound advice for a superintendent. Yet for a 16-year-old in Ogdensburg or Elmira choosing between a second science course and a CTE elective, it points to a system that finalizes its rules only after the decision is locked in.

Juniors who would ordinarily sit for a Regents exam in June face a narrower version of the same uncertainty. A passing score may count toward an endorsement that has not been defined, may matter to an admissions office reading a transcript from a district it has never seen under the new system, or may simply feed the state's federal accountability data, and the student taking the test has no way to know which.

The Exams Stay. Their Purpose Changes.

The Regents exams are not disappearing, and students should hear that plainly. The department's own announcement said "Regents examinations will continue as rigorous statewide measures of student achievement," and the state is working with the federal Education Department on testing that satisfies federal accountability requirements. What changes is that passing scores stop being a separate condition of the diploma.

The Advanced Designation is moving too, from a separate diploma type to a seal or endorsement on the single diploma. Chalkbeat reported that New York City students can still take Regents exams to earn that advanced designation, but the regulation that will define how the seal is earned under the new rules has not been written, which is precisely the kind of detail a junior aiming at a selective SUNY campus or an out-of-state college needs before deciding whether to sit for one more exam.

Then there is the credential that serves students most likely to fall through a transition. The September Regents item retires the 4+1 pathway structure without naming the CDOS Commencement Credential, the work-readiness credential that our September guide to the 216-hour CDOS requirement walked through for families. Students who count on that credential are also owed an answer before senior year, not after it.

Who Is Asking for the Same Thing

The concern does not come from one side of the reform debate. Jeff Smink, deputy director of policy and advocacy at Education Trust-New York, told Chalkbeat the state should keep the exam requirement until districts have local assessment strategies in place, and he warned that graduation numbers could rise without showing whether students are ready. Eric Dinowitz, who chairs the City Council's education committee, put the risk in a sentence: "Without a replacement of equal or more rigor, it's going to turn into a checklist."

New York State United Teachers, which supports the direction of the changes, has been just as direct about execution. "As this work moves forward, the details will matter," NYSUT President Melinda Person said after the September vote.

Chancellor Lester W. Young Jr. framed the overhaul around fairness, saying that "a student's zip code, background, or circumstance never determines their opportunities for success." A diploma built on hundreds of separately designed local assessment strategies is where that promise will be tested, because a district with a curriculum office and a performance assessment coordinator will build something very different from a rural district where one counselor may cover every student from grade 7 through grade 12.

What Albany Can Do Before the Regulation

None of this requires the Regents to slow down. The department can publish, this school year, the floor every local assessment strategy must meet, including how many sources of evidence count toward a course, who scores performance tasks, and how a district checks that its grading means the same thing from one classroom to the next.

The department already publishes rating guides and conversion charts for the Regents exams it administers, and teachers across the state grade those exams against the same rubrics. Local assessment will need public scaffolding of the same kind if a diploma earned in Watertown is going to carry the same weight as one earned in Yonkers.

It can also require each district to post its strategy where students and parents can read it before spring course selection, a step that costs little and gives a junior in Plattsburgh the same visibility as one in Brooklyn. And it can state now how the Advanced Designation seal will be earned and what becomes of the CDOS credential, two answers that do not depend on the rest of the regulation being finished.

The September 14 vote gave staff until February to bring proposed amendments, and the Regents will take public comment once they do. The students those amendments will govern are already in their junior-year classrooms, and some of them will be registering for senior-year courses before the comment period closes.