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Updated July 29, 2025, at 5:43 p.m.
Harvard will turn over I-9 forms for nearly all employees in response to an inquiry by the Department of Homeland Security, the University’s human resources office wrote in an email to current and recent employees on Tuesday afternoon.
The University will not immediately turn over information on students who are currently or were recently employed in roles open only to students. Harvard is evaluating whether those records are protected by the Family Educational Rights and Privacy Act, according to the Tuesday email.
An I-9 form is a federal document used to verify a person’s authorization to work in the United States. All employers must complete and retain an I-9 for every employee, who are required to attest to their citizenship or immigration status and provide supporting documentation.
On July 8, a day before it publicly announced its intent to subpoena Harvard for documents on international students, the DHS served Harvard with a separate subpoena asking for payroll information, a roster of employees, and a point of contact who could supply I-9 forms for workers who were employed by Harvard between July 1, 2024, and July 1, 2025.
The DHS sent Harvard an accompanying notice of inspection demanding I-9 forms for University employees who worked in Massachusetts Hall.
Harvard initially interpreted the request as applying only to the “few dozen” employees who work in Mass. Hall, home to the office of University President Alan M. Garber ’76.
But the DHS later notified Harvard that the notice of inspection “applies to all current Harvard employees and any individual employed by the University in the last 12 months.” The email to University employees did not specify when Harvard received the second notification.
Harvard employs roughly 19,000 individuals, according to the University’s website.
Under federal regulations, the DHS may conduct I-9 form inspections and require U.S. employers to make them available for inspection. The July 8 notice of inspection gave Harvard three days to turn over the requested information.
A University spokesperson declined to comment on Tuesday afternoon.
Harvard Human Resources wrote that it has asked the DHS to confidentially handle all information submitted by Harvard in response to the request.
“We have asked DHS to confirm that the records produced in response to this notice for any individual will be securely maintained by DHS and not shared outside DHS, that the documents will only be accessed by DHS personnel authorized to inspect such records, and that DHS will only use these records for the purposes authorized by law,” the email read.
The DHS also served Harvard with a set of three separate subpoenas seeking information primarily on international students’ post-graduation employment, participation in protests, and criminal and disciplinary records.
The Harvard International Office wrote on July 10 that it was evaluating the subpoenas and would comply with U.S. laws and University policy.
“If the University determines we must provide such records that pertain to you, the University will contact you directly,” the HIO wrote on their website.
The Trump administration has tried to use international students as a bargaining chip in its campaign to obtain deep concessions from Harvard. The administration has argued, without providing evidence, that international students pose a national security risk and launched repeated investigations into Harvard’s compliance with immigration and visa law.
In the spring, the DHS targeted Harvard’s authority to host students and researchers under the Student and Exchange Visitor Program, a program that maintains international student records for F-1 and J-1 visa holders.
And on Wednesday last week, the State Department launched a separate investigation into Harvard’s participation in the Exchange Visitor Program, which permits the University to sponsor J-1 visas for international instructors, researchers, and some students.
But Harvard is far from the only institution that has faced I-9 inspections as part of the Trump administration’s immigration crackdown. The Trump administration has used I-9 audits to exact multimillion-dollar fines from companies that employed unauthorized workers.
Correction: July 29, 2025
A previous version of this article stated that the subpoena asked for I-9 forms. In fact, the subpoena asked for a point of contact to request I-9 forms, but the notice of inspection that asked for the I-9 forms themselves carries independent legal authority.
—Staff writer Samuel A. Church can be reached at samuel.church@thecrimson.com. Follow him on X @samuelachurch.
—Staff writer Cam N. Srivastava can be reached at cam.srivastava@thecrimson.com. Follow him on X @camsrivastava.
