' JHU Online Education Checklist | JHURA

Website Navigation for Screen Readers

Click to Return to Homepage

JHU Online Education Checklist

Country Compliance Considerations


This checklist sets forth the legal, compliance and business considerations you are expected to review prior to engaging with a new partner or providing new online educational services, whether in a particular country or a global offering.

JHU’s Risk and Compliance offices, including the Office of General Counsel and the Export Control & Facility Security Office, should be consulted prior to initiating new online programs and non-US partners, including working through this Checklist.

1.      Are there US legal restrictions/prohibitions that apply to online education (as a “service”) in [Country Name]?

  • US export controls? (Will information provided be something other than general science, math or engineering principles commonly taught in university catalog courses?)
  • US economic sanctions? (Will educational services be provided to persons from or in certain regions/countries to which sanctions programs apply?)
  • Does the vendor that facilitates online access to your services reserve the right to “block” access by students located in certain countries?

2.      Does [Country Name] require a foreign university to obtain regulatory approval or registration from the government before it may provide an entirely online program?

  • From what government entities?
  • Is this requirement applicable during the COVID-19 pandemic?

3.      Will the proposed JHU online program include any on-site faculty or instruction component that we need to consider as part of this analysis?

o  *Unlikely to apply during the COVID-19 pandemic

4.      Would JHU have a “partner” or online education “provider” with which it is working to deliver the services?

  • If yes, is it a US company or foreign company?
  • Have we determined that there are reputational issues or concerns raised (publicly in media accounts, or by peers/others) about a proposed partner?
  • Does the company have experience offering online education in foreign countries (if a US company)? If so, what benchmarks has the company provided?

5.      Does [Country Name] consider the provision of online education to be subject to a Sales Tax or a Value-Added Tax (VAT) (where online ed. is considered a “service”) under its tax laws?

  • If yes, do we need to gross up the internal costs for the proposed program to cover?
  • If yes, are these taxes applicable during the COVID-19 pandemic?
    • Example: China waived VAT applicable to online education during

6.      Does [Country Name] recognize credentials earned online from a foreign university (where a majority or entire course load is online)? Example: 1-year graduate degree from  JHU.

  • If yes, then are there regulatory disclaimers or statements that need to be made?
  • If no, is there an exception during the COVID-19 pandemic?
  • If no, are there disclaimers that JHU needs to make to the students so that they are aware that the degree may not be recognized?

7.      Does [Country Name] have laws in place that restrict or monitor (“censor”) certain topics that may be considered politically, religiously, socially or otherwise “sensitive”?

o  If so, what is the obligation on JHU to follow/not follow the law(s)?

8.      Is [Country Name] subject to General Data Protection Regulations (GDPR) (e.g., EU), which could affect the collection and use of personal data from students participating in online programs?

o  If yes, do local laws require data localization or enhanced obligations on data controllers, etc.?

9.      Would engaging in an entirely online education program in [Country Name] create a permanent establishment (PE) for JHU?

  • Generally, a PE exposes the foreign entity [JHU] to corporate income tax on revenue attributable to that
  • Does the US have a tax treaty with [Country Name]?
  • Does JHU already have a presence in [Country Name]?

10.  Does [Country Name] have any restrictions on students (who are in-country) paying large sums of money to an entity outside of the country?

  • Example: China has restrictions on outflows of money above USD $50,000.


Johns Hopkins University
Research Administration

1101 E. 33rd Street, C310
Baltimore, MD 21218

(443) 927-3073
Email: jhura@jhu.eduSend an email to jhura@jhu.edu

  • Contact Us

    • This field is for validation purposes and should be left unchanged.
  • Website Footer Navigation