Staying compliant with I-9 and E-Verify requirements is more than a regulatory obligation. It is a critical part of protecting your business from costly fines and penalties. Conducting a regular I-9 and E-Verify self-audit helps identify errors before they become compliance issues and demonstrates a good-faith effort to comply with federal and state employment verification requirements.
1. Gather Your I-9 and E-Verify Records
Collect all active employee Form I-9s, retained forms for terminated employees still within the retention period, and all related E-Verify case records.
2. Review Every Form I-9
- Verify Section 1 was completed by the employee on or before the first day of work.
- Verify Section 2 was completed within three business days of the employee’s start date.
- Check signatures, dates, and required fields.
- Confirm document information is accurate and legible.
- Ensure reverification was completed when required.
- Verify that the correct version of the I-9 was used.
- Ensure I-9s are stored securely and separately from other personnel records.
- Confirm supporting documents are consistently saved.
3. Compare Your I-9s to Your Employee Roster
Confirm every employee who requires an I-9 has one on file and dispose of records only after the required retention period has expired. The retention period is the later date of one year after termination or three years after hire.
4. Review Your E-Verify Cases
- Confirm every required employee has an E-Verify case.
- Verify cases were created within required timeframes.
- Ensure Tentative Nonconfirmations (TNCs) were handled properly.
- Confirm all cases were closed with the correct final status.
5. Correct Errors the Right Way
Follow USCIS guidance when correcting forms. Never use correction fluid or erase entries. Draw a single line through incorrect information, enter the correction, then initial and date it. If a form contains multiple errors, complete a new I-9 and keep it with the original and a written explanation. Do not destroy the original I-9 if a new one is completed.
6. Document the Audit
Record when the audit was performed, who completed it, findings, and corrective actions taken. This documentation supports your organization’s good-faith compliance efforts. Save the audit log and individual audit memos along with the I-9s and E-Verify documents.
Why Annual I-9 and E-Verify Self-Audits Matter
Routine I-9 and E-Verify audits help reduce legal risk, improve recordkeeping, prepare your organization for potential government inspections, and provide confidence that your hiring practices comply with federal and state requirements.
Need Help with Your I-9 Compliance?
An experienced compliance review can uncover issues that are easy to overlook and provide practical recommendations before an external audit occurs. Contact us today if your company needs assistance with completing an I-9 and E-Verify self-audit.
