DHS Plans Major Overhaul of Information Collected on School and Student Forms

On 03.Sep.2025, the U.S. Department of Homeland Security (DHS) published a notice in the Federal Register proposing significant revisions to the information collected on the petition for approval of school for attendance by nonimmigrant student (form I-17), and the certificate of eligibility for nonimmigrant (F-1 and M-1) student status (form I-20). The changes would expand the range of data schools must provide to the Student and Exchange Visitor Program (SEVP) and add new reporting requirements for students. A public comment period runs until 03.Nov.2025.

Key Proposed Revisions

For schools, the form I-17 would be restructured to capture greater detail about ownership, enrollment, program delivery methods, and designated school official (DSO) roles. The form would also require clearer reporting on program-level data, including online and hybrid instruction, and whether curricular practical training (CPT) is built into a program.

For students, the form I-20 would include new fields covering guardianship of minors, the date of degree conferral, specifics about financial support, and whether coursework or employment is conducted online, remotely, or in person.

Practical Implications for Schools

If these changes are finalized, they would impact school in a number of ways, including the following:

• Greater administrative burden – DSOs may need to collect, verify, and update more detailed information, particularly about program structures and enrollment figures. For smaller schools with limited staffing, this could increase compliance workloads significantly.
• More scrutiny of academic offerings – By requiring disclosure of delivery modes and program structures, SEVP may more closely examine schools that rely heavily on online or hybrid models. Institutions could face questions about whether their programs align with visa requirements for in-person study.
• Expanded reporting on DSOs – Schools will need to provide more transparency about the role and employment status of DSOs. This may discourage schools from appointing part-time DSOs or those with limited institutional authority.
• Potential costs – Breaking down tuition and expenses by degree level or program may require schools to develop new financial reporting mechanisms.

Practical Implications for Students

For students, the impact could also be felt in several ways:

• Increased oversight of online and remote activities – Students will need to formally document whether their studies or employment take place online or off-site, potentially tightening enforcement of rules limiting distance learning.
• Closer tracking of financial resources – By asking for more precise details on the source and type of funding, DHS may scrutinize student financial eligibility more closely, which could complicate cases where students rely on varied or informal sources of support.
• Additional requirements for minors – Legal guardians of younger F and M students would need to provide detailed information, which may complicate the process for families sending children to U.S. schools.

Broader Considerations

These proposals reflect a continuing trend toward greater data collection and oversight in the SEVP system. While DHS may argue that the changes will improve program integrity and help identify fraud, they likely will increase compliance obligations for both schools and students. Institutions may need to review internal processes to ensure accurate reporting, while students should be prepared for more detailed inquiries into their academic and financial situations.

Comment Opportunity

DHS is requesting input from schools, students, and the public on whether the proposed revisions are necessary, whether the burden estimates are accurate, and how the forms might be improved or streamlined. Stakeholders have until 03.Nov.2025 to submit comments.

Conclusion

The proposed revisions to forms I-17 and I-20 represent a significant expansion in the data required of schools and students under SEVP. Stakeholders in the international education community, including schools, students, designated school officials, and immigration attorneys, may wish to review the proposed changes closely and submit comments before the 03.Nov.2025 deadline.

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