An analytical model based on complex variable theory is proposed to investigate ground responses due to shallow tunneling in multi-layered ground with an arbitrary ground surface load. The ground layers are assumed to be linear-elastic with full-stick contact between them. To solve the proposed multi-boundary problem, a series of analytic functions is introduced to accurately express the stresses and displacements contributed by different boundaries. Based on the principle of linear-elastic superposition, the multi-boundary problem is converted into a superposition of multiple single-boundary problems. The conformal mappings of different boundaries are independent of each other, which allows the stress and displacement fields to be obtained by the sum of components from each boundary. The analytical results are validated based on numerical and in situ monitoring results. The present model is superior to the classical model for analyzing ground responses of shallow tunneling in multi-layered ground; thus, it can be used with assurance to estimate the ground movement and surface building safety of shallow tunnel constructions beneath surface buildings. Moreover, the solution for the ground stress distribution can be used to estimate the safety of a single-layer composite ground.