The regulations prohibit applicants from updating household size, number in college or dependency status due to a change in the applicant's marital status (34 CFR 668.55(a)(3)).

FAFSA on the Web, however, allows students to change the answer to the question regarding marital status. Financial aid administrators should look for comment code 75 to identify such students. Students are only allowed to correct errors in their marital status as of the application date, not update it for changes after the application has been submitted. If there is any question, the financial aid administrator should ask for a copy of the marriage certificate and compare the date of the certificate with the FAFSA's application date.

See also Changes in Household Size and Dependency Status.

The most likely reason for not allowing changes in the student's marital status to lead to updates is to provide stability in the EFC calculations. Most of the other potential causes of a dependency status change are permanent state changes that do not result in a flip-flop. For example, birth of a child, becoming a veteran, and becoming an orphan generally do not change back and forth. Marital status is the only one that could potentially change many times throughout the year. (Technically, the snapshot philosophy of need analysis entails allowing no changes. So rather than disallowing updates caused by a change in the student's marital status, the regulations are simply not allowing it as an exception, presumably because a change in the student's marital status could affect the student's dependency status, leading to significant changes in financial aid eligibility.)

It is not appropriate to use professional judgment to update a student's marital status due to a change after the application date, unless there is a special circumstance that justifies the change. A change in the student's marital status is not, in and of itself, a special circumstance, not even if it happens the day after the FAFSA was completed.

On the other hand, most schools would consider death of a spouse to be a sufficient special circumstance to merit an adjustment. Technically, the adjustment is occuring not because of a change in marital status, but rather because of the death of a wage-earner. The involuntary nature of the change is also a justification. Likewise, if the spouse was incarcerated or there was a court protection from abuse order, that would be the special circumstance that justified an adjustment, not the change in marital status.

If the student failed to sign and date the original FAFSA application, they might try to argue that the data on the application should be updated to reflect their marital status as of the date the application is signed. It is up to the financial aid administrator to choose which date to use: the original date the FAFSA was submitted, or the date it was signed. Most financial aid administrators would choose the original submission date, as that is the date the application was completed, and the signature is merely attesting to the accuracy on that date. That's why the FAFSA asks for the date the form was completed and not the date it was signed.