I-9 Self-Audit Program & Checklist (eLearning Module)

Form I-9 verifies an employee’s identity and authorization to work in the United States as required by federal law. Failure to comply can lead to serious penalties. As of January 2, 2025, fines range from $288 to $2,861 per form for paperwork violations, $590 to $4,730 for document abuse, and up to $28,619 per unauthorized worker for knowingly employing individuals without proper authorization.

Every U.S. employer must complete Form I-9 for all employees hired after November 6, 1986, including both citizens and noncitizens. This applies to anyone who works for wages or other compensation, whether they are full-time, part-time, or temporary.

Employees must complete Section 1 of Form I-9 no later than their first day of work for pay. Employers must review the employee’s documents and complete Section 2 within three business days of the employee’s start date.

Employees complete Section 1, entering personal details and confirming their work authorization. Employers complete Section 2 by reviewing original documents and recording verification details within three business days. Supplement B (formerly Section 3) is used by employers to reverify work authorization or record rehires.

Frequent errors include missing signatures or dates, incomplete fields, accepting expired or invalid documents, failing to finish Section 2 on time, using white-out, or asking for specific documents. Employers should also avoid using outdated I-9 forms and ensure all information is legible and accurate.

Yes, Form I-9 can be completed and stored electronically. Since 2004, federal regulations permit employers to use electronic systems that meet Department of Homeland Security standards, including proper electronic signatures and secure storage. Employers may also use a combination of paper and electronic systems.

Regular self-audits help employers identify and fix errors early, avoid costly penalties, and show good-faith compliance to federal authorities. They also improve record accuracy, strengthen internal controls, and reduce risk during an official Immigration and Customs Enforcement (ICE) audit.

To correct errors, draw a single line through incorrect information, write the correction nearby, and initial and date it. Do not use correction fluid. For multiple or major errors, attach a new form with an explanation. Employees must correct Section 1 errors; employers correct Sections 2 and Supplement B.

Reverification occurs when an employee's work authorization expires. Employers must complete Supplement B (formerly Section 3) no later than the expiration date of the employee's employment authorization. The employee must present a List A or List C document showing current work authorization. U.S. citizens and lawful permanent residents do not require reverification.

Employers must retain Form I-9 for three years after the date of hire or one year after employment ends, whichever is later. Forms may be stored in paper, electronic, microfiche, or microfilm format, but must be made available for government inspection within three business days of a request.

Employers should conduct routine internal audits, ensure forms are complete, store I-9s separately from personnel files, and correct any errors immediately. HR staff should be trained on compliance procedures and ready to provide all requested forms within three business days of receiving a Notice of Inspection.

HR staff should receive training that covers current I-9 requirements, acceptable documents, verification procedures, correction methods, and reverification steps. Training should include practical examples, periodic refreshers, and internal audits. Using compliant electronic I-9 systems with built-in validation checks helps prevent common errors.