Form I-9, a key employment verification document in the United States, has come under renewed public attention after Harvard University confirmed it will hand over thousands of these forms to the US Department of Homeland Security (DHS). The move follows a federal inspection notice and is part of a broader scrutiny of employment and immigration compliance in the US.
What is Form I-9?
Form I-9, officially known as the Employment Eligibility Verification form, is a mandatory document used by all US employers to verify the identity and employment authorization of individuals they hire, regardless of citizenship or immigration status.
The form is required under federal law and is regulated by the US Citizenship and Immigration Services (USCIS).
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Who must complete it?
Every employee hired in the United States must complete Section 1 of Form I-9 on their first day of work. At the same time, the employer is responsible for completing Section 2 within three business days of the employee’s start date.
This requirement applies to:
What does the form include?
On the form, employees must attest to their citizenship or immigration status and provide original documents that prove both their identity and eligibility to work. This could include:
Remote verification option
As of recent updates, employers may also choose to verify documents remotely using a DHS-authorized alternative procedure. If they do, they must check a box on the form indicating that the inspection was conducted virtually.
Why is Harvard handing over I-9 Forms?
The issue came into the spotlight in July 2025, when the DHS issued a notice of inspection to Harvard University requesting I-9 forms for all employees who worked between July 2024 and July 2025, as reported by Harvard Crimson. This request was part of a broader federal investigation into employment verification and compliance with immigration laws.
Harvard initially interpreted the request as limited to a few dozen staff members based at Massachusetts Hall, where the university president's office is located. However, DHS later clarified that the request applied to all 19,000 employees hired in the past year.
While the university has agreed to share these records, it is still evaluating whether to disclose I-9 information for student employees, citing potential protection under the Family Educational Rights and Privacy Act (FERPA).
Why is Form I-9 important for employers and employees?
Employers who fail to properly complete, retain, or produce I-9 forms during inspections can face significant fines. Similarly, employing unauthorized workers can lead to criminal penalties and reputational damage.
For employees, the information they provide, especially their work authorization documents, must be accurate and up-to-date. Any discrepancies can result in delays, job denials, or further review by immigration authorities.
What happens during an inspection?
When DHS issues a notice of inspection, employers usually have three business days to produce their I-9 records. These records must be made available either in physical or digital form, depending on how the employer manages them.
Employers may also request confidentiality. In Harvard's case, the university stated it asked DHS to ensure that any submitted records would be securely maintained, used only by authorized personnel, and not shared outside the agency.
The increased attention on I-9 forms is part of a larger trend under the Trump administration, which has been pursuing stricter enforcement of immigration rules, particularly in the workplace. Audits and inspections have been used to investigate whether employers are knowingly hiring individuals without legal work authorization.
Harvard is not the only institution facing such scrutiny, but it is one of the most high-profile. For both employers and employees, the case serves as a reminder of the central role Form I-9 plays in immigration compliance across the US job market.
What is Form I-9?
Form I-9, officially known as the Employment Eligibility Verification form, is a mandatory document used by all US employers to verify the identity and employment authorization of individuals they hire, regardless of citizenship or immigration status.
The form is required under federal law and is regulated by the US Citizenship and Immigration Services (USCIS).
(Join our ETNRI WhatsApp channel for all the latest updates)
Who must complete it?
Every employee hired in the United States must complete Section 1 of Form I-9 on their first day of work. At the same time, the employer is responsible for completing Section 2 within three business days of the employee’s start date.
This requirement applies to:
- US citizens
- Lawful permanent residents
- Non-immigrants with work authorization
- Any other individuals employed in the US
What does the form include?
On the form, employees must attest to their citizenship or immigration status and provide original documents that prove both their identity and eligibility to work. This could include:
- A US passport
- A Permanent Resident Card (Green Card)
- An Employment authorization document
- A combination of a driver’s license and social security card
Remote verification option
As of recent updates, employers may also choose to verify documents remotely using a DHS-authorized alternative procedure. If they do, they must check a box on the form indicating that the inspection was conducted virtually.
Why is Harvard handing over I-9 Forms?
The issue came into the spotlight in July 2025, when the DHS issued a notice of inspection to Harvard University requesting I-9 forms for all employees who worked between July 2024 and July 2025, as reported by Harvard Crimson. This request was part of a broader federal investigation into employment verification and compliance with immigration laws.
Harvard initially interpreted the request as limited to a few dozen staff members based at Massachusetts Hall, where the university president's office is located. However, DHS later clarified that the request applied to all 19,000 employees hired in the past year.
While the university has agreed to share these records, it is still evaluating whether to disclose I-9 information for student employees, citing potential protection under the Family Educational Rights and Privacy Act (FERPA).
Why is Form I-9 important for employers and employees?
Employers who fail to properly complete, retain, or produce I-9 forms during inspections can face significant fines. Similarly, employing unauthorized workers can lead to criminal penalties and reputational damage.
For employees, the information they provide, especially their work authorization documents, must be accurate and up-to-date. Any discrepancies can result in delays, job denials, or further review by immigration authorities.
What happens during an inspection?
When DHS issues a notice of inspection, employers usually have three business days to produce their I-9 records. These records must be made available either in physical or digital form, depending on how the employer manages them.
Employers may also request confidentiality. In Harvard's case, the university stated it asked DHS to ensure that any submitted records would be securely maintained, used only by authorized personnel, and not shared outside the agency.
The increased attention on I-9 forms is part of a larger trend under the Trump administration, which has been pursuing stricter enforcement of immigration rules, particularly in the workplace. Audits and inspections have been used to investigate whether employers are knowingly hiring individuals without legal work authorization.
Harvard is not the only institution facing such scrutiny, but it is one of the most high-profile. For both employers and employees, the case serves as a reminder of the central role Form I-9 plays in immigration compliance across the US job market.
