Company Name:
Audit Coordinator:
Audit Date:
Total Employees Audited:
Audit Preparation
Generate a roster of all active employees from the HRIS system to use as the master checklist for the I-9 audit.
Retrieve every I-9 form from physical files and electronic storage so each employee's form can be individually reviewed.
Download the latest version of Form I-9 and the handbook for employers from the USCIS website for reference during the audit.
Brief everyone involved in the audit on proper I-9 completion, acceptable documents, reverification rules, and common error types.
Set up a spreadsheet to log each employee's I-9 status, any errors found, corrective actions taken, and completion dates.
Section 1 Review - Employee Information
Check that the employee's full name, address, date of birth, citizenship status, and signature are present and legible.
Verify the date in Section 1 is on or before the employee's first day of work as required by federal regulation.
Ensure the employee selected the correct citizenship or immigration status box and provided any required document numbers.
If someone helped the employee complete Section 1, confirm the preparer or translator certification block is properly filled out and signed.
Document all errors such as blank fields, incorrect dates, or missing signatures and prepare them for proper correction.
Section 2 Review - Employer Verification
Confirm the employer completed Section 2 within three business days of the employee's first day of employment.
Verify that the document title, issuing authority, number, and expiration date match acceptable documents from the I-9 lists.
Ensure the employee presented documents from List A, or a combination from List B and List C, as required by the form.
Check that the authorized employer representative signed and dated Section 2 and that their printed name and title are included.
Verify the employer did not request more or different documents than required, which could indicate discriminatory practices.
Section 3 Review - Reverification
Identify employees with expiring work authorization documents and confirm that timely reverification was completed in Section 3.
Confirm that Section 3 was completed on or before the expiration date of the employee's work authorization document.
For rehired employees, verify that Section 3 was properly completed with the new hire date and updated document information.
Check that the I-9 form version used for reverification is the current version accepted by USCIS at the time of completion.
Error Correction and Remediation
Draw a single line through incorrect information, write the correction, and initial and date the change following official correction procedures.
When an existing form has too many errors to correct cleanly, complete a new I-9 and attach it to the original with an explanation.
Record every error found and correction made in the audit tracking spreadsheet with details on the nature of the issue and resolution.
Contact employees whose I-9 forms are missing or substantially incomplete and arrange for proper completion as soon as possible.
Use the current date when making corrections or completing new forms and never alter the original dates on any I-9 documentation.
Audit Finalization and Compliance
Summarize the total number of forms reviewed, errors found by category, corrections made, and any outstanding issues in a final report.
Confirm that I-9 forms are stored separately from personnel files and retained for the required period after employment ends.
Determine the correct disposal date for each former employee's I-9 using the later of three years from hire or one year from termination.
Update I-9 procedures, provide additional training, and create quality checks to prevent the errors uncovered during the audit.
Set a calendar reminder for the next internal I-9 audit, ideally within 12 months, to maintain ongoing compliance.
An I-9 audit checklist is a step-by-step guide for conducting an internal review of your organization's Form I-9 records to ensure compliance with federal employment eligibility verification requirements. It helps identify errors, missing documents, and procedural gaps before a government inspection occurs. Regular I-9 audits protect organizations from fines that can reach thousands of dollars per violation.
I-9 violations are among the most common and costly employment compliance failures, with ICE conducting thousands of audits annually. Common errors include missing signatures, expired documents, incorrect section timing, and improper storage practices. This checklist provides a systematic approach to reviewing every I-9 on file and correcting issues in a legally defensible manner.
The checklist covers audit preparation and scope definition, Section 1 employee information review, Section 2 employer verification review, Section 3 reverification and rehire assessment, document acceptability verification, retention schedule compliance, error correction procedures, and audit documentation and reporting. It also includes guidance on handling common I-9 errors found during audits.
Use the Brief view for routine quarterly spot checks of recent I-9s and the Detailed view for a comprehensive audit of all I-9s on file. Customize the checklist to reflect your organization's I-9 storage method — paper or electronic — and your E-Verify participation status. Download and share with your HR compliance team and legal counsel before beginning the audit.