What is an Internal I-9 Audit? And 5 Reasons to Audit Now

In this series, we discuss why your organization should consider performing an internal I-9 audit and review steps you can take to help protect your organization.

This is the first of a four-part series for HR professionals, called "Internal I-9 Audit and Remediation Best Practices." In this series, we discuss why your organization should consider performing an internal I-9 audit. We will also review steps you can take to help protect your organization and make the process more efficient.

What is an internal I-9 audit?

An internal I-9 audit or an I-9 self-audit is not required by law, but is often used as a best practice to help manage I-9 compliance.  An internal I-9 audit is the systematic review of your organization's Forms I-9 to identify missing I-9s, incomplete I-9s and I-9s with issues. This is an opportunity to make any necessary corrections, and:

  • Make corrections in accordance with U.S. Citizenship and Immigration Services (USCIS) procedures
  • Review your organization's I-9 management process
  • Ensure proper procedures are in place to help keep your organization in compliance

5 Reasons Now is the Time for an Internal I-9 Audit

  1. Worksite Enforcement is Rising - U.S. Immigration and Customs Enforcement (ICE) is delivering on its promise to increase worksite enforcement. In fact, I-9 worksite enforcement has already tripled and ICE is on pace for an increase more than 443%.”
  2. Paper I-9s are Risky - According to an industry expert with Jackson Lewis, an estimated 60-80% of paper I-9s are missing, incomplete or have errors. If you are using paper I-9s today or still have a lot of paper I-9s in your database, then there is a good chance you have issues with your files.
  3. It Could Cost You - Fines nearly doubled in August 2016 and have increased even more since that time.  With as few as 50 annual new hires a year, an organization could face a potential penalty of nearly $130,000. An organization with 10,000 annual new hires could be looking at over $25,000,000 in potential penalties.* The fines can stack up quickly as you can see in our chart below.
  4. Being Proactive Helps - ICE considers five factors when determining penalties, including whether there was a good faith effort to comply. Performing an internal audit to find mistakes and correct them can help show your progress toward compliance.
  5. No Time to Waste - ICE can give as few as three days’ notice before an inspection. That’s often not enough time to get all your documents in order.  You should start correcting any issues with an internal audit now, so you help reduce your exposure for the future.

Read the other articles in our series, "Internal I-9 Audit and Remediation Best Practices:"

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* based on annual new hire x 3-year retention x 70% error rate x $1,230 average fine