# Use-of-Force Reporting Requirements *Version 1.0 · Status: Current · Date: October 19, 2026* ## The Federal Framework The FBI's National Use-of-Force Data Collection (NUOFD) launched in 2019 as the first systematic federal effort to collect use-of-force data from law enforcement agencies nationwide. Participation is voluntary. As of 2022, agencies covering approximately 65% of the US population submitted data -- meaning roughly 35% did not. The program cannot produce a nationally representative count of use-of-force incidents; it produces a count from participating agencies only. The program collects data on incidents involving: any firearm discharge, any use of force resulting in death or serious bodily injury, and any use of force resulting in a complaint. Less serious force -- takedowns, strikes, use of chemical spray -- is reported at agency discretion under a separate "summary" track. The Death in Custody Reporting Act (DCRA) of 2013 requires states to report deaths occurring in law enforcement custody as a condition of certain federal funding. Compliance is inconsistent, penalties have not been enforced, and the scope excludes force-related deaths that occur outside custody. ## State Mandates State use-of-force reporting requirements vary across four dimensions: **Trigger threshold** -- what level of force triggers a report. Some states require reports for any use of force; others only for force resulting in injury; others only for deadly force. **Reporting entity** -- whether the officer, supervisor, or agency submits the report, and to whom (internal records only, state attorney general, independent oversight body, or public database). **Timeliness** -- reporting deadlines range from 24 hours (for deadly force) to 30 days or more for less serious incidents. Late or amended reports are common. **Public availability** -- a minority of states publish use-of-force data in accessible form. Most collect it without making it available for independent analysis. As of 2024, fewer than half of states have enacted comprehensive use-of-force reporting mandates covering all levels of force. Several states enacted new requirements following 2020, with variable implementation quality. ## What Gets Reported vs. What Occurs Use-of-force reports document incidents that officers classify as use-of-force under agency policy -- not all force that objectively occurs. This creates three systematic gaps: **Classification discretion** -- whether a given action (a firm grip, a push, a compliance hold) is classified as reportable force depends on how the agency defines force in policy and how officers interpret that definition. Narrow definitions produce low counts; broad definitions produce high counts. Cross-agency comparisons are unreliable without policy-level analysis. **Supervisor review gaps** -- in agencies without mandatory supervisor review of force reports, underreporting is structurally incentivized. Officers bear the burden of self-reporting conduct that may result in discipline. **Soft-force undercounting** -- less-than-lethal force options (chemical agents, CEWs, physical control techniques) are systematically underreported relative to firearm deployments in nearly every study that has compared administrative records to BWC or ICV footage. ## What Good Reporting Looks Like Effective use-of-force reporting systems share five features: 1. **Low trigger threshold** -- any intentional physical contact beyond a handshake requires documentation; force is not defined by outcome 2. **Independent submission pathway** -- officers document force; supervisors review and counter-sign; neither can unilaterally suppress a report 3. **Standardized data elements** -- subject demographics, officer demographics, force type, injury outcome, and whether BWC was activated are collected on every report 4. **Timely supervisor review** -- force reports are reviewed within 24--48 hours, not aggregated at end of quarter 5. **External publication** -- aggregate data is published on a regular schedule in machine-readable format; incident-level data is available to researchers and oversight bodies under appropriate protocols ## The Relationship to Pattern-or-Practice Investigations DOJ pattern-or-practice investigations under 34 U.S.C. § 12601 routinely find that internal use-of-force reporting significantly undercounts actual force. The standard method is to compare administrative force reports against BWC footage, ICV footage, and supervisor use-of-force logs for the same time period. Gaps of 20--40% between documented force and observable force are common findings. This is not primarily a deliberate-falsification problem. It is a policy design problem: agencies that define force narrowly, require self-reporting without independent review, and do not audit against available footage produce structurally incomplete records regardless of individual officer intent. ## The Bottom Line A use-of-force reporting system that only captures what officers choose to report is not an accountability mechanism -- it is a count of self-disclosed incidents. The quality of use-of-force data in any agency is a direct function of three policy decisions: how force is defined, who reviews reports before they are finalized, and whether reported counts are audited against available footage. Agencies serious about accountability treat force reporting as a verification system, not an honor system.