New Poll: 66% of Employers Lack a Proactive Form I-9 Audit Plan

Amid shifting federal rules and increased audit enforcement, form I-9 compliance is a growing concern for HR teams. During our recent webinar, Beyond Penalties: Adapting to New I-9 Audit Standards, we asked over 1,500 attendees about their biggest operational headaches and their current audit strategies.

Here is what their responses revealed.

Challenge #1: Fixing Past I-9 Mistakes Is One of HR's Biggest Headaches

Question: Which area of I-9s presents the greatest operational challenge today?

• 38.7% — Correcting historical I-9 errors

• 26.0% — Keeping up with changing I-9 and E-Verify rules

• 16.1% — Tracking work authorization and reverifications

• 10.3% — Maintaining onboarding efficiency

• 8.9% — Managing remote/virtual verification

Takeaway:

Nearly 39% of respondents say they struggle with historical I-9 errors, the exact issue government audits may target for fines.¹ Combined with the challenge of keeping up with rule changes, over 64% of employers are bogged down by basic compliance maintenance rather than focusing on higher strategic priorities.

Challenge #2: Nearly two in three Companies Lack a Mature I-9 Audit Process

Question: How would you describe your organization's current approach to internal I-9 audits?

• 33.9% — We have a mature audit and remediation process in place

• 29.2% — We mainly address issues as they arise

• 20.9% — We conduct audits but struggle with follow-up

• 13.7% — We're interested in auditing but haven't fully started

• 2.4% — We don't find that auditing is needed

Takeaway:

Only 34% of poll respondents say they have a mature audit and remediation process in place. A combined 63.74% are either reactive, addressing issues only as they arise, or they’re struggling to complete the follow-through on gaps they've already identified. In other words, nearly two thirds of employers are operating without a mature audit and remediation process in place. This is at a time when ICE has redefined "substantive" I-9 violations, reclassifying several common errors in ways that might trigger immediate monetary penalties.

Three Action Steps for Employers

Given these findings, a move from reactive to a more proactive stance could be imperative. Here are three steps HR and compliance teams can take to help strengthen their I-9 programs.

1. Schedule Regular Internal Audits

Don't wait for an official notice from the government. Routine internal audits can help you catch mistakes in Section 1 and Section 2 before an inspector does. Proactively identifying and correcting I-9 errors before an inspection can demonstrate good faith and help reduce exposure to paperwork fines and penalties.  

2. Follow Proper Correction Rules

Corrections should be initialed, dated, and logged according to federal guidelines. Maintaining a detailed audit trail, including the name of the person making changes, the date changes were made, and a description of the changes, can help ensure greater transparency and better support the integrity of your Form I-9 records. 

3. Automate Tracking

Manually tracking employment authorization expiration dates and reverification deadlines can be challenging, especially for employers with remote or distributed workforces. Automated Form I-9 management solutions can help you identify upcoming reverification requirements, send timely reminders, and help you reduce your risk of missed deadlines. 

Conclusion

The numbers tell a consistent story: most organizations know I-9 compliance is a growing risk, but the majority are still addressing it reactively. With federal enforcement intensifying and the definition of a "substantive" violation expanding, the cost of waiting appears to be going up.

The good news? Being proactive doesn’t mean rebuilding your program from scratch. Regular audits, proper correction procedures, and the right automation can go a long way toward helping you reduce your risk. Equifax offers a suite of I-9 solutions designed to help, from electronic I-9 management and historical conversion to remediation support. If you're among the 66% still finding your footing, it may be worth exploring how the right tools can help you improve your audit readiness.

1 U.S. Immigration and Customs Enforcement. (2026, August 31). Form I-9 Inspection Under Immigration and Nationality Act § 274A. U.S. Department of Homeland Security.

The information provided is intended as general guidance and is not intended to convey any tax, benefits, or legal advice. For information pertaining to your company and its specific facts and needs, please consult your own tax advisor or legal counsel.  Equifax provides services that can help employers reduce their compliance risks. Details on our provision of these services and related support will be contained in your services agreement. Links to sources may be to third party sites. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.