I-9 Audit Checklist
Form I-9 audit checklist for HR compliance teams conducting internal I-9 reviews. This audit template helps you systematically review employee eligibility forms, identify common errors (missing signatures, incorrect dates, photocopying failures), and create corrective action plans before ICE inspections.
Pre-Audit Planning
□ Determine audit scope (full workforce vs. random sample)
□ Select 10% of I-9 forms or minimum 100 forms for review
□ Assign audit team and schedule completion timeline
□ Review current I-9 form version (check USCIS website)
□ Prepare audit tracking spreadsheet
Section 1 Review (Employee Portion)
□ Verify employee signature and date (must be by first day of work)
□ Check all required fields completed (name, address, DOB, SSN)
□ Confirm citizenship/immigration status attestation checked
□ Review preparer/translator certification if applicable
□ Flag any missing information or signatures
Section 2 Review (Employer Portion)
□ Verify completion within 3 business days of hire date
□ Confirm List A document OR List B + List C documents examined
□ Check document title, number, and expiration dates recorded
□ Verify employer signature and date present
□ Review photocopies match recorded information (if applicable)
Section 3 Review (Reverification/Rehire)
□ Check reverification completed before work authorization expires
□ Verify new documentation examined and recorded
□ Confirm rehire information completed if applicable
□ Check employer signature and date on Section 3
Common Errors to Flag
□ Missing signatures or dates
□ Section 2 completed late (after 3 business days)
□ Incorrect document list combinations
□ Blank fields in required sections
□ Photocopying prohibited documents
□ Expired work authorization not reverified
□ Using outdated I-9 form versions
Corrective Actions
□ Document all errors found in audit log
□ Calculate error rate by violation type
□ Create correction plan with timeline
□ Update forms with missing information (add memo)
□ Implement training for HR staff on common errors
□ Schedule follow-up audit in 6-12 months
How the I-9 Audit Checklist works
Select a random sample of I-9 forms (10% of workforce or minimum 100 forms). Review Section 1 completion dates, Section 2 documentation requirements, and reverification for work authorization expiration. Document all errors, calculate violation rates, and implement corrections within 30 days.
ICE targets employers with I-9 violations, issuing fines of $272-$2,701 per form error. Internal audits identify and fix issues before government inspection. Companies conducting annual I-9 audits reduce violation rates by 80% and demonstrate good-faith compliance efforts.
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