University I-9 Audits: What HR Must Know in 2025

Higher Education I-9 Compliance: Why Universities Face Rising Audit Risk in 2025

In July 2025, Harvard University was ordered to turn over nearly 20,000 I-9 forms to the Department of Homeland Security (DHS). The Harvard I-9 Inspection sparked national attention, but it wasn’t an isolated case—it was part of a broader enforcement trend.

Higher education institutions are now squarely in ICE’s audit crosshairs. With tens of thousands of faculty, staff, researchers, and student workers—often across multiple campuses—the potential for I-9 errors is high.

The Unique Challenges of Higher Education I-9 Compliance

Unlike many industries, universities face complex compliance scenarios:

• Large, Decentralized Workforces: HR processes vary across departments, schools, and satellite campuses.
• High Turnover Roles: Student employees cycle in and out every semester, creating frequent onboarding and offboarding.
• International Hires: Many universities employ foreign faculty, researchers, and graduate assistants requiring strict visa tracking and reverification.
• Paper-Based Legacy Systems: Many institutions still rely on outdated, manual I-9 processes that increase error rates.

This combination makes colleges particularly vulnerable during an I-9 audit.

What an I-9 Audit Means for Universities

When ICE issues a Notice of Inspection (NOI), institutions have just three business days to produce:

• All I-9 forms (for current and terminated employees within the retention window)
• Payroll and tax records
• Hiring policies and procedures
• E-Verify records (if enrolled)

A single clerical error—like a missing signature or late verification—can carry fines of up to $2,861 per violation in 2025. For large universities with thousands of employees, the financial exposure can be devastating.

Recent Enforcement Trends in Higher Education

The Harvard case is just the beginning. Immigration attorneys report a sharp increase in audits across major metropolitan areas and sanctuary cities. Institutions with federal research funding or large international student populations are particularly at risk.

How Universities Can Reduce I-9 Risk

To strengthen compliance in 2025, HR leaders in higher education should:

1. Centralize I-9 Management

Move away from department-level recordkeeping. A digital I-9 compliance platform ensures consistency and fast retrieval.

2. Audit Your Records Now

Run an internal audit to catch errors before ICE does. Even a 10% error rate in a 5,000-person workforce could lead to millions in potential fines.

3. Standardize Training Across Campuses

Ensure hiring managers, department administrators, and student employment offices all follow the same rules.

4. Track International Reverification

Build automated reminders for visa expirations to prevent costly reverification mistakes.

5. Prepare an Audit Response Plan

Designate who will respond to an NOI, where I-9s are stored, and how quickly they can be produced.

Higher Education Isn’t Exempt from I-9 Enforcement

The Harvard case proves that no institution is too prestigious—or too large—to escape ICE’s focus. Universities that act now can reduce risk, protect their employees, and avoid reputational damage.

Want to understand your exposure? Try our I-9 Risk Calculator.

Need expert guidance? Book a free I-9 compliance assessment with our team.