What If DHS Revoked a University’s SEVP Certification? A Hypothetical Case with Real Implications
Imagine this: A major U.S. university suddenly receives notice from the Department of Homeland Security (DHS) that its certification under the Student and Exchange Visitor Program (SEVP) has been revoked. The notice cites vague concerns: campus unrest, antisemitism allegations, and supposed ties to a foreign government. More specifically, DHS claims the university failed to produce certain student records.
Within 24 hours, thousands of international students face the possibility of losing their legal visa status.
This is a hypothetical scenario—but it’s rooted in very real legal frameworks. And every SEVP-certified school should be paying close attention.
SEVP Certification: Why It’s Non-Negotiable for U.S. Schools
SEVP, overseen by U.S. Immigration and Customs Enforcement (ICE), allows certified institutions to enroll international students through programs that issue Form I-20. That form is the basis for an F-1 or M-1 visa application.
If a school loses its SEVP certification:
It can no longer legally support international students
Students risk losing their status
The institution may suffer enormous reputational and financial damage
Legal Response to Sudden SEVP Revocation
In the situation above, a university would almost certainly file a federal lawsuit. The primary claims would likely include:
Violation of the Administrative Procedure Act (APA)
Denial of due process under the Fifth Amendment
Under the APA, federal agencies can’t act in ways that are “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” If DHS revoked SEVP status without warning, justification, or adherence to its own policies, the university could argue its actions were unlawful.
To protect students and halt enforcement, the university would also likely seek a Temporary Restraining Order (TRO)—a short-term court order that blocks the agency’s action until the legal issues can be reviewed.
Courts Grant TROs When:
The petitioner is likely to succeed on the merits
The harm is irreparable (such as mass visa loss)
The public interest favors immediate pause
The balance of harms supports equitable relief
A TRO would temporarily restore the school’s SEVP certification, giving both the institution and its international students breathing room while the case moves forward.
Why This Hypothetical Should Still Matter to You
This may be a fictional case—but it reflects real and growing pressure on U.S. universities to remain fully compliant with SEVP protocols, especially in an era of heightened scrutiny related to:
National security concerns
Political tensions and foreign affiliations
Data transparency and student record-keeping
The fallout from even a temporary SEVP disruption can devastate not just institutional operations—but the lives of thousands of students and families.
What SEVP-Certified Institutions Should Do Now
Proactive legal and operational compliance is the best protection. Schools should:
Audit SEVP compliance policies regularly
Ensure student data is accurate, timely, and complete
Document all communications and responses to DHS inquiries
Prepare a rapid-response legal and media strategy in case of agency action
Even if no issues are currently pending, schools should have internal protocols in place to handle potential audits, Notices of Intent to Withdraw Certification, or emergency DHS communications.
What International Students and Families Should Know
International students typically have no control over a school’s SEVP status—but their visa depends on it. That’s why students should:
Know their transfer and reinstatement options
Maintain accurate contact and program info in SEVIS
Have a plan in place in case of unexpected changes
Understand their rights under U.S. immigration law
Losing status doesn’t always mean removal. But acting fast—and with legal guidance—can be critical.
If You’re Facing SEVP Compliance Issues, You Don’t Have to Handle It Alone
At Zachary W. Anderson Law, we represent both international students and SEVP-certified institutions across Nebraska and beyond. Whether you’re dealing with a records request, worried about your compliance policies, or navigating a sudden status change, we provide strategic, compassionate legal support rooted in deep knowledge of immigration and administrative law.
Immigration Compliance Isn’t Optional—But Support Is Available
The scenario above may be hypothetical. But the consequences it describes are very real.
If you’re a school administrator, designated school official (DSO), or international student dealing with SEVP issues, now is the time to get proactive.
Contact Zachary W. Anderson Law at 402-259-0059 or zach@zandersonlaw.com to schedule a confidential consultation. We’ll walk you through your rights, your risks, and your options—so you can stay focused on education, not uncertainty.