By Anonymous Contributor | POLITICO Education / Tech & National Security Desk

A potential sale of the world’s most widely used English-language proficiency exam is raising alarms across the U.S. policy, education, and national security communities.

Sources close to Educational Testing Service (ETS), the nonprofit operator of the TOEFL exam, say the organization has recently engaged in early-stage discussions to divest its TOEFL unit — a move that could open the door to acquisition by foreign entities, including firms linked to nations considered strategic competitors to the United States.

The possible transaction, though unannounced, is already prompting concern over the data governance, education integrity, and geopolitical implications of placing TOEFL under foreign control.

“TOEFL is not just a test. It’s a global gateway to the U.S. higher education system — and a treasure trove of personal and academic data,” said one senior education policy advisor who requested anonymity to speak about nonpublic conversations.

A Global Database of Student Biometrics and Scoring Algorithms

TOEFL processes and stores sensitive data on more than 35 million test takers across 180+ countries — including passport scans, facial recognition for remote proctoring, academic transcripts, real-time keystroke logs, and IP-based location tracking. That dataset has quietly become one of the largest international education intelligence assets in the world.

Analysts say this alone could put any sale within the scope of the Committee on Foreign Investment in the United States (CFIUS), which increasingly reviews transactions involving biometric data, AI decision engines, and critical infrastructure in education and communications.

“We would consider TOEFL’s infrastructure to be covered under critical data-processing for foreign-student mobility,” said a former Treasury Department CFIUS analyst.

“Any foreign acquisition, particularly from rival nations, would demand close review.”

U.S. Universities in the Crossfire

Universities across the U.S. continue to rely on TOEFL as the default English-language requirement for international admissions. A shift in ownership could expose the U.S. education system to data breaches, political leverage, or scoring manipulation — especially if the acquiring party has a financial or strategic interest in steering global student flows.

Some insiders are already warning of potential political asymmetries.

“Imagine a state-linked investor controlling access to the scores that determine whether a student from Africa, India, or Latin America can get into MIT,” said one cybersecurity researcher at a Washington think tank.

Lack of Transparency and NDA Concerns

Several international education companies have reported being asked to sign Non-Disclosure Agreements in preliminary meetings related to the transaction, with no clear information about buyer identity, regulatory disclosure, or compliance protocols.

The silence is raising eyebrows.

“If ETS is truly considering foreign divestiture of a tool so central to American soft power, the public has a right to know who is on the other side of the table,” said a former State Department education attaché.

A New Era of CFIUS Education Scrutiny?

While CFIUS traditionally focused on sectors like semiconductors and telecommunications, recent moves suggest an expanded lens. The 2020 TikTok review and the 2023 forced divestiture of a Saudi investment in a U.S. AI tutoring firm signal a clear pivot toward education-tech and data.

A potential TOEFL transaction could be the first major CFIUS intervention in global testing and credentialing, a space worth more than $20 billion annually.

“This is a new battleground,” says a senior advisor to the Senate Intelligence Committee.

“Control over who gets into America’s universities — and how that decision is calculated — is a national strategic asset.”

Experts also warn that transferring ownership of such a critical evaluation system could weaken long-standing academic partnerships and disrupt student mobility pipelines. Many universities depend on trusted, transparent testing systems to maintain fairness in admissions. Any ambiguity surrounding TOEFL’s governance or data handling could force institutions to reassess their reliance on the exam, potentially reshaping global education pathways for years to come.