DHS Overhauls School and Student Forms for 2025–2026 Reporting

(UNITED STATES) The U.S. Department of Homeland Security (DHS) and the U.S. Department of Education have moved forward with sweeping changes to the data schools must collect and report about international students and domestic admissions, opening public comment periods and aiming to begin enforcement in the 2025–2026 academic year. DHS published a proposal on September 3, 2025 to overhaul data fields on Form I-17 (school certification for nonimmigrant students) and Form I-20 (certificate of eligibility for F-1/M-1 student status), with a public comment deadline of November 3, 2025. In parallel, the Department of Education issued expanded admissions reporting rules through the Integrated Postsecondary Education Data System (IPEDS), with a comment deadline of October 14, 2025 and immediate applicability for institutions seeking Title IV funds.

The White House also issued a directive on August 7, 2025, under President Trump, requiring broader transparency from federally funded institutions and barring race-based admissions. That directive sets a tight 120-day timeline for the Secretary of Education to finalize and publish new reporting rules.

DHS / SEVP proposals: what changes to Form I-17 and Form I-20 would look like

DHS’s proposal focuses on more detailed school-level and student-level reporting within the Student and Exchange Visitor Program (SEVP). The agency would require schools to provide more granular information in SEVIS, the government database that tracks F-1 and M-1 students.

Key proposed changes to Form I-17 (school-level):
– Expanded ownership details for institutions.
– Disaggregated enrollment counts by program.
– Specification of delivery modes: online, hybrid, and in-person formats.
– Clearer role descriptions for Designated School Officials (DSOs).
– Program-specific fields, including whether Curricular Practical Training (CPT) is built into a program.
– Robust accounting of tuition and expenses, broken out by degree or program.

Key proposed changes to Form I-20 (student-level):
– New fields for minors’ guardianship arrangements.
– Expected degree conferral dates.
– Detailed financial backing categories (personal funds, family support, scholarships, sponsorship).
– The mode of coursework and employment engagement (in person, online, or remote).

According to DHS materials, the intention is to tie school certification more closely to actual program design and delivery, and to link individual student records to precise financial and academic realities.

Context and enforcement implications

• SEVP’s effort follows a period of policy volatility around SEVIS records.
• Tricia McLaughlin, a DHS spokesperson, said recent restorations of some SEVIS records were temporary while policy is developed.
• ICE is working on a framework for future SEVIS record terminations; current records remain active until new guidance is issued.
• These new data fields could shape how SEVP weighs school compliance and student status in the next enforcement cycle.

Department of Education: expanded IPEDS admissions reporting

The Department of Education’s IPEDS changes will affect thousands of colleges and universities. Key features of the proposed IPEDS rule:

• All four-year institutions with selective admissions (1,762 schools) must submit:
  • Five years of disaggregated historical data plus current-year data.
  • Data disaggregated by race-sex pair across applicants, admits, and enrollees.
• Reporting covers:
  • First-time undergraduates, transfer students, and graduate students.
  • Remedial or non-credit coursework taken by new enrollees (new fields).
• Applicability:
  • Submission is mandatory for institutions that want to keep Title IV eligibility.
  • The Department published a Federal Register docket (ED-2025-SCC-0382) describing the collection details and asking whether open-enrollment schools should be included later. Federal Register docket (ED-2025-SCC-0382)

The White House August 7 directive bans race-based admissions and requires public-facing admissions metrics. It directs the Secretary of Education to publish expanded reporting within 120 days—placing the publication target by early December 2025.

Practical impacts on schools and students

Administrative and operational burdens:
– DSOs, admissions officers, and institutional research teams will face new workloads.
– Smaller institutions with lean staffing will be most affected.
– Schools must track program format changes and manage online/hybrid offerings carefully to keep Form I-17 accurate.
– For Form I-20, international offices will need tighter coordination with registrar, bursar, and academic departments to maintain accurate financials and degree timelines.

Technical and cost implications:
– Reprogramming student information systems, learning management platforms, and data warehouses will take time and money.
– Staff training and new reporting tools may be necessary to map local codes to federal fields.
– Institutions have raised concerns about data integrity, privacy risks in small subgroups, and the burden of linking multiple data sources.

Privacy and disclosure risks:
– The more granular the data, the higher the risk that individuals in small programs can be identified when data are published.
– Legal counsel, privacy advocates, and ed tech leaders warn of increased audits, possible challenges to admissions practices, and the need for stronger privacy protocols.

Student-facing impacts:
– International students may be asked for more proof of financial support and clearer documentation on coursework and training modes.
– Form I-20 updates could trigger more follow-up from consular officers or U.S. Customs and Border Protection if forms show heavy online loads or remote work plans.
– F-1 minors could face extra paperwork for guardianship, especially when handled across borders.
– Families should plan earlier and keep detailed records, as these details will be entered into SEVIS and reflected on the Form I-20.

How the proposed changes would be applied in practice

For Form I-17:
– Schools must keep updated ownership records.
– Enrollment counts must be disaggregated by program.
– Delivery modes (online/hybrid/in-person) must be documented.
– DSOs must have clear role definitions to avoid ambiguity.
– Program fields identifying embedded CPT could influence how officers view work authorization plans.
– Tuition and expense reporting must be broken out by degree level or program.

For Form I-20:
– Schools must capture guardianship for minors, degree conferral dates, and precise financial sources.
– Records must indicate whether coursework or employment occurs in person, online, or remotely.
– Students listing remote work or heavy online loads may be subject to closer review to ensure compliance with limits on online classes and practical training rules.

For IPEDS:
– Institutions must produce five prior years plus the current year of admissions data, disaggregated by race-sex pair, and covering applicants, admits, and enrollees.
– The dataset extends to transfer and graduate students, and includes remedial/non-credit coursework indicators.
– The Department expects technical upgrades at IPEDS and NCES to handle larger volumes and add accuracy checks.

Implementation timeline and comment periods

Critical dates:
– DHS public comment deadline for Form I-17 and Form I-20: November 3, 2025.
– Department of Education comment deadline for IPEDS expansions: October 14, 2025.
– White House directive timeline: 120 days from August 7, 2025 (publication by early December 2025).
– Agencies aim to begin enforcement in the 2025–2026 academic year; final DHS rulemaking will follow comment review.

Both agencies have indicated more guidance will follow as systems are upgraded.

Recommended actions for institutions

For international/student services and DSOs:
1. Build a data map for every new Form I-17 field and assign an owner to validate updates each term.
2. Update internal Form I-20 templates and workflows to capture guardianship for minors, degree conferral dates, and financial sources with document checks.
3. Create a flag in the student information system for online or remote activity that triggers review against F-1/M-1 limits.
4. Draft plain-language notices for students explaining why schools request new documents and how records will be protected.

For institutional research and admissions teams:
1. Extract five years of admissions data and test disaggregation by race-sex pair for applicants, admits, and enrollees across undergraduate, transfer, and graduate populations.
2. Coordinate with admissions, registrar, and finance to define fields consistently, including remedial and non-credit coursework indicators.
3. Pilot submissions to catch errors early and document a quality-control checklist before final upload.
4. Develop a data governance plan covering definitions, update cycles, and chain of custody for sensitive files.

Leadership and governance:
– Brief boards and senior leaders on compliance risks: immigration status for international students and Title IV eligibility.
– Form a cross-functional team (DSO office, institutional research, admissions, registrar, legal counsel, IT) to track rulemaking, coordinate comments, and guide implementation.
– Schedule internal audits and spot-checks of underlying records; document methods for handling incomplete applications or mid-cycle policy changes.

What stakeholders should submit in public comments

Agencies encourage detailed, constructive feedback. Suggested comment topics:
– Technical challenges and costs associated with system upgrades.
– Privacy risks, especially for small cell sizes and race-sex pair disclosures.
– Proposed alternatives or guardrails for public releases where small subgroups may be identifiable.
– Whether open-enrollment institutions should be included and, if so, on what timetable.
– Practical suggestions to align new fields with existing campus systems to minimize duplicate reporting.

VisaVerge.com analysis notes that early, detailed comments can shape final rules, particularly when they propose workable alternatives or identify conflicts with existing systems.

Student and family preparation checklist

Students and families should gather:
– Proof of funds: bank statements, scholarship letters, sponsor affidavits.
– Documentation of planned online coursework and a plan for meeting full-time enrollment rules.
– Guardianship documents for minors (with translations if needed).
– A timeline for degree conferral to help DSOs enter accurate dates on Form I-20.

Consular interview prep:
– Be ready to explain how in-person requirements will be met if Form I-20 indicates significant online coursework or remote training.
– M-1 applicants should be able to describe hands-on components and the physical location of training.

Privacy, legal, and technical concerns

• Stakeholders warn that granular reporting increases the risk that individuals in small programs may be identified, especially with multi-year disaggregation by race-sex pair.
• Legal and compliance teams expect more audits and possible challenges to admissions practices as data become more public and detailed.
• Ed tech leaders call for clearer privacy protocols and stronger internal controls; a 2025 report emphasized the need for plain-language notices when data flows increase.
• Technical teams note that legacy student information systems may require custom coding, stretching budgets.

Where to find official notices and resources

Stakeholders can find official notices and submit comments via the Federal Register: https://www.federalregister.gov/.

For SEVP-specific references and guidance, see ICE resources:
– ICE page on Form I-17: https://www.ice.gov/sevis/i17
– ICE overview of Form I-20: https://www.ice.gov/sevis/i20

Note: Form I-17 is filed in SEVIS and not downloaded like a standard form; the ICE pages explain the petition process for school approval and ongoing duties. The Form I-20 page covers issuance rules and when forms require reprints or updated records.

Final recommendations and next steps

• Set internal deadlines two to three weeks before federal comment dates to allow senior review and last-minute adjustments. (Plan to file DHS comments by mid-October and IPEDS feedback by early October.)
• Communicate clearly and often with campus communities—students, parents, and staff—using short, direct notices in plain language about new document requests and privacy protections.
• Prepare cross-functional teams to track the rulemaking, implement changes, and brief leadership.
• Inventory data, test reporting pipelines, and update policies now so the institution can adapt smoothly when final rules and guidance are issued.

Important deadlines and timetables:
– DHS comment deadline for SEVP/Forms I-17 and I-20: November 3, 2025
– Department of Education comment deadline for IPEDS expansions: October 14, 2025
– White House directive publication target: 120 days from August 7, 2025 (early December 2025)
– Targeted enforcement: 2025–2026 academic year

The federal push seeks richer data to inform immigration oversight and admissions transparency. The proposed Form I-17 and Form I-20 revisions push schools to document program design and student engagement more precisely, while IPEDS expands public reporting on admissions across student groups. The process is already underway; institutions and students that prepare now—mapping fields, testing systems, tightening workflows, and protecting privacy—will be better positioned when agencies move from proposals to enforcement for the 2025–2026 academic year.