About 62 million people notified of the 2024–2025 Conduent data breach are covered by a proposed $80 million class action settlement that a New Jersey federal judge has not approved. On October 22, 2026, the judge asked for more information, due November 5, and there is no claim form or deadline yet.
Update, October 23, 2026: Judge Asks for More Before Approving
On October 22, 2026, U.S. District Judge Michael E. Farbiarz issued a two-page opinion and order on the plaintiffs’ motion for preliminary approval of the $80 million settlement. He did not grant it. The court generally requires evidence with case-specific detail on each of the Girsh factors, the test federal courts in the Third Circuit use to judge whether a class settlement is fair, and on each of Rule 23’s requirements, and the order found the filings did that in some respects but not others:- Risk of proving liability: the papers gave the court virtually none of the underlying information, such as the key documents and witnesses, that it needs to weigh the strengths and weaknesses of the claims on its own.
- Total possible recovery: the court said it could not assess the $80 million figure without knowing the larger baseline of total possible damages and how that baseline was calculated.
- Monitoring: the judge asked what direct cash relief was given up to secure the monitoring every class member would receive, and how much people generally pay for that kind of service.
- Leftover money: the agreement sends any residual funds to a cy pres recipient; the order suggests deciding how to handle leftover money later, after the first payments are made.
- Notices: the proposed class notices were filed only in English.
The plaintiffs have until November 5, 2026 to file new or supplemental materials. The order does not reject the settlement; the court will consider the motion again once those materials are filed. Until preliminary approval is granted, the court has not appointed a settlement administrator, no notices go out and no claims are being accepted, so a message seeking a fee or payment information in exchange for a Conduent settlement payment does not come from the settlement.
The Proposed $80 Million Agreement
Conduent, the back-office contractor that handles printing, mailroom and payment work for health plans and government programs, agreed on October 16, 2026 to pay $80 million to resolve the consolidated class actions over its 2024–2025 data breach. The plaintiffs filed the agreement with a motion for preliminary approval in the U.S. District Court for the District of New Jersey the same day, and Conduent disclosed it in an SEC filing.The settlement agreement puts the number of people whose information was in the stolen files at about 62 million, far above the 10.5 million figure first reported for health insurance customers. Conduent denies the allegations and says the settlement is not an admission of fault or liability. Nothing can be claimed yet: the court still has to approve the deal before notice goes out and a claim form opens.
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What the Proposed Settlement Would Provide
The $80 million fund is non-reversionary, meaning none of it goes back to Conduent. It also pays for monitoring services, settlement administration and any attorneys’ fees and service awards the court approves. The agreement splits the class into two groups based on how the exposed data was stored:- Subclass A (about 40 million people): people whose information was in files the agreement describes as maintained in a complex manner that was not readily accessible to third parties. They would receive one year of credit monitoring automatically, with no claim required.
- Subclass B (about 22 million people): people whose information was in files where the data was readily accessible. They would receive one year of medical data monitoring automatically, and could also claim a pro rata share of the remaining fund with no documentation. Subclass B members who lived in California on October 21, 2024 would get a 20% increase on that pro rata payment.
- Documented losses (both subclasses): reimbursement of up to $3,500 for unreimbursed losses from fraud or identity theft that were more likely than not caused by the breach, with supporting documents. A personal statement alone does not count as documentation under the agreement.
The pro rata payment comes from what is left after administration costs, documented-loss payments and court-awarded fees, so its size will depend on how many valid claims are filed. Conduent has also committed to maintain added security measures. Monitoring codes, according to the proposed notice, can only be activated after final approval. Under the agreement, class counsel would ask the court for attorneys’ fees of up to 34% of the fund plus costs, and the proposed order lists service awards of up to $1,500 for each class representative; all of those come out of the fund and need the court’s approval.
Who Would Be in the Settlement Class
The proposed class is all individuals residing in the United States who are on the class list and were sent actual or substitute notice by Conduent or one of its clients that their information may have been affected. For most class members, Conduent held their information because of services it provided to their current or former health plan; for a smaller number, it came through an employer or a government benefits program.The proposed email notice would tell each person which subclass they are in and include their monitoring activation code. Epiq Class Action & Claims Solutions is the proposed settlement administrator. The release would cover Conduent, its affected clients and those clients’ affected customers, which includes the insurers named in the litigation.
Proposed Timeline
The proposed order ties every deadline to the date the court grants preliminary approval, which has not happened yet:- Notice begins 40 days after preliminary approval
- Claim form deadline: 75 days after notice begins
- Opt-out and objection deadline: 90 days after notice begins
- Final approval hearing: a date in 2027 left blank for the court to set
Because the court did not grant preliminary approval on October 22, 2026, none of these dates has started to run, and the schedule cannot begin until the court rules on the supplemental filings due November 5. OpenClassActions.com will publish a full settlement page with the official website, claim form and exact deadlines once the court approves the notice.
Background: The Conduent Breach
According to the settlement agreement, Conduent discovered on or about January 13, 2025 that an unauthorized third party had been in its network since about October 21, 2024 and had taken files containing personal information. Depending on the person, the files included some combination of names, Social Security numbers, addresses, dates of birth, medical information, health insurance information and financial account information.Notification letters from Conduent and its clients began going out in October 2025. More than 30 proposed class actions followed in federal and state courts, beginning around October 27, 2025. The federal cases were consolidated in New Jersey, where amended complaints filed in March and June 2026 named Conduent and several of its clients, including health insurers. The complaints alleged inadequate cybersecurity and delayed notice; those claims were never decided, because the parties settled before a ruling on the merits.
Earlier, Conduent offered affected people two years of free credit monitoring and identity restoration through its own notification program, with a March 31, 2026 enrollment deadline. That offer was separate from the proposed settlement.
Case Information
- Case: In re: Conduent Business Services Data Breach Litigation, No. 2:25-cv-16953
- Court: U.S. District Court, District of New Jersey
- Judge: Hon. Michael E. Farbiarz (Magistrate Judge Alex D. Silagi)
- Defendants settling: Conduent Business Services, LLC; Conduent State & Local Solutions, Inc.; Conduent Incorporated
- Settlement fund: $80 million, non-reversionary
- Class size: about 62 million people (Subclass A about 40 million; Subclass B about 22 million)
- Proposed administrator: Epiq Class Action & Claims Solutions, Inc.
- Status: Preliminary approval motion filed October 16, 2026; not granted in an October 22, 2026 order (ECF 175), which set a November 5, 2026 deadline for supplemental materials
- Proposed attorneys’ fees: up to 34% of the fund, plus costs, subject to court approval
- Claim form: Not available yet
Questions
Is there a Conduent data breach settlement?
A proposed one. Conduent signed an $80 million class action settlement on October 16, 2026, and plaintiffs asked the federal court in New Jersey to grant preliminary approval the same day. On October 22, 2026, the judge did not grant approval and gave the plaintiffs until November 5, 2026 to file more information. Until the court approves it, there is no settlement website, no claim form and no deadline.
Why didn’t the judge approve the Conduent settlement?
In an October 22, 2026 order, U.S. District Judge Michael E. Farbiarz said the filings did not give the court enough case-specific information to evaluate the deal. He asked for more on the risks of proving liability, the total damages the class could have recovered and how that figure was calculated, the cash given up in exchange for monitoring and what monitoring generally costs, and notices in languages other than English. He also suggested deciding later what happens to any leftover money. The order did not reject the settlement.
Can a Conduent settlement claim be filed now?
No. Claims are not open. The court has not approved the settlement or appointed a settlement administrator, so no one is accepting Conduent settlement claims, and no legitimate claim process charges a fee to receive a payment. Notice and a claim form would come only after the court grants preliminary approval.
Who would be covered by the Conduent settlement?
The proposed class is all individuals residing in the United States who are on the class list and were sent actual or substitute notice by Conduent or one of its clients that their information may have been affected by the data incident. The agreement puts the class at about 62 million people, split into Subclass A (about 40 million) and Subclass B (about 22 million).
What would the Conduent settlement pay?
Under the proposed agreement, Subclass A members would automatically get one year of credit monitoring and Subclass B members one year of medical data monitoring. Members of both subclasses could claim up to $3,500 for documented losses tied to fraud or identity theft. Subclass B members could also claim a pro rata cash payment without documentation, with a 20% increase for those who lived in California on October 21, 2024.
How would class members know which subclass they are in?
According to the proposed notice, the settlement email notice will say which subclass each person is in and will carry the monitoring activation code. The proposed notice says people who do not receive an email notice can ask the settlement administrator, Epiq Class Action & Claims Solutions, whether they are on the class list.
Does Conduent admit wrongdoing?
No. Conduent denies the allegations, and its October 16, 2026 SEC filing says the settlement is not an admission of fault or liability. The agreement resolves the claims without any court finding on who is right.
Sources
- Opinion and Order on the motion for preliminary approval, ECF 175, filed October 22, 2026 (CourtListener)
- CourtListener docket — In re Conduent Business Services Data Breach Litigation, No. 2:25-cv-16953 (D.N.J.)
- Conduent Incorporated Form 8-K, filed October 16, 2026 (SEC)
- Class Action Settlement Agreement and Release, D.N.J. No. 2:25-cv-16953, ECF 173-2 (SEC exhibit)
