by Strategic HR Partners


by Strategic HR Partners

Self Auditing the Form

According to Immigration and Customs Enforcement (ICE), employers are increasingly conducting internal audits of their I-9 forms. Internal I-9 audits are not required by law but can be extremely helpful to employers. Employers may choose to review all forms or a sample of forms based on neutral and nondiscriminatory criteria, according to the guidance. If a subset of I-9 forms is audited, the employer should consider carefully how it chooses those forms to avoid retaliating against workers or discriminating against employees based on their citizenship status or national origin.

  • Employers should inform employees in writing that an internal audit of I-9 forms will take place and explain the scope and reason for the audit, the guidance recommends.
  • Only employees should correct errors or omissions in Section 1 of the form. Only employers should correct errors or omissions in Sections 2 and 3.
  • Corrections should be made by drawing a line through the incorrect information, entering the corrected or omitted data, and initialing and dating the correction.
  • Employers should complete a new I-9 as soon as possible if the form was never completed or is missing.

Employers are required to accept original Form I-9 documentation that “reasonably appears to be genuine” and that relates to the person presenting the documentation. If employers conclude during an audit that a document does not appear to be legitimate, they are instructed to address any concerns with the employee and provide him or her the opportunity to choose a different document to present.

All these tips can save you from big fines down the road; for more information, visit


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