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Internal I-9 Audit: A Best-Practices List

Currently, the Immigration and Customs Enforcement or ICE, which is the enforcement arm of The Department of Homeland Security, is intensifying immigration compliance audits in the workplace. These efforts begin with an audit of I-9 forms. To avoid severe penalties for noncompliance, many employers regularly conduct I-9 audits.

Here is a quick list of important considerations for an internal I-9 audit.

  1. Before beginning your internal audit, establish procedures to ensure the audit will be conducted in a non-discriminatory manner.

  2. Make sure the the internal audit is not based on the employee’s race or national origin. Either audit all forms or audit a truly random sample. A company may not selectively choose the forms to include in the audit.

  3. Conduct routine audits. This provides a defense against allegations of targeted internal I-9 auditing. It not only verifies I-9 forms on file, but it also trains your human-resources department for actual government-compliance audits.

  4. An employer must either keep copies of all I-9 verification documents or keep none of them. If your records are not complete, then you must either obtain missing documentation or destroy all collected verification documents.