Harvard I-9 Inspection Highlights Rising Employer Risk | i9 Intelligence

Harvard’s I-9 Audit: A Wake-Up Call for Every Employer

This summer, Harvard University—the fifth largest employer in Massachusetts—was ordered to turn over thousands of employee work authorization forms (I-9s) to the Department of Homeland Security (DHS). The July 8th “notice of inspection” demanded records for current and recent employees, sparking concern across higher education and beyond.

While Harvard’s case is high-profile, the reality is this: every employer in the U.S. can face similar scrutiny—and the financial fallout can be devastating.

What Happened at Harvard?

DHS issued a formal request for I-9 documentation for nearly 20,000 employees, allowing just days to comply. These forms contain sensitive data: name, address, Social Security number, and attestations of work eligibility.

Historically, I-9 inspections have been rare—even immigration attorneys report seeing only a few in decades of practice. But the trend is shifting. As immigration enforcement ramps up nationwide, even prestigious institutions are not immune to audits that can expose recordkeeping errors and trigger significant penalties.

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"People see 'Harvard under DHS audit' and think this is about politics. I don't think it is—ICE issued over 6,000 of these notices last year alone. The average fine for I-9 paperwork violations? Around $2,200 per form. Do the math on your employee count—that's your exposure sitting in your filing cabinet right now." — Jed Butler, CEO i9 Intelligence

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The Hidden Financial Risk of I-9 Audits

The latest DHS penalty schedule increased fines to nearly $3,000 per violation, meaning a single clerical error multiplied across a large workforce could lead to millions in liability.

For context:

• A company with 500 employees and a 10% error rate could face up to $150,000 in fines.
• For Harvard’s 20,000 employees, even a 5% error rate could lead to millions in potential penalties.

Errors include:

• Missing forms for past employees
• Incomplete or late verifications
• Incorrect document details or signatures

These mistakes are easy to make, especially for organizations relying on paper-based processes or inconsistent training across multiple hiring managers.

Why This Matters Beyond Harvard

This case sets a precedent: if DHS will audit a world-renowned institution, every business—from universities to farms to franchise restaurants—should prepare for increased enforcement.

Employers in high-turnover industries (hospitality, construction, agriculture, staffing) face even higher risk due to frequent hiring, decentralized teams, and varied verification processes.

The Harvard audit also signals a shift toward broader subpoenas—not just targeting suspected unauthorized workers but reviewing the employer’s entire compliance program for errors.

How Businesses Can Protect Themselves

Avoiding six-figure fines starts with proactive compliance:

1. Centralize I-9 Management: Use a digital I-9 platform that standardizes processes and flags errors before they happen.
2. Conduct Internal Audits: Regular self-audits identify gaps before DHS does.
3. Train Every Hiring Manager: Consistency matters—errors often stem from misunderstanding the rules.
4. Prepare for an Inspection: Know where your I-9s are stored, who will respond to DHS, and how to supply records quickly and accurately.

Related: How to Prepare for ICE Worksite Raids

Calculate Your Company’s I-9 Risk

Think your company is safe? Many employers discover costly errors only after an audit notice arrives.

Use our free I-9 Risk Calculator to estimate potential fines based on your workforce size and current practices.