In February 2012 the US Department of Education (ED) granted 11 states the first round of waivers from some of the requirements of the Elementary and Secondary Education Act (ESEA) in exchange for other commitments. As the Data Quality Campaign (DQC) noted in "Why Data Matter in ESEA Reauthorization: Recommendations to ensure data are used to improve student achievement," nearly every high-priority item in national, federal, state, and local discussions on improving ESEA--and in proposals from across the political spectrum--requires high-quality longitudinal data for its design, implementation, and evaluation. The recently announced ESEA waivers are no different. This analysis summarizes the waiver requirements, highlights some of the data and data system implications, and notes DQC observations (where applicable) about states' data capacity to address those issues.