Confirm that each employee completed Section 1 of Form I-9 no later than their first day of employment for pay, including full legal name, address, date of birth, Social Security number (if applicable), and citizenship/immigration status attestation.

Review each I-9 to ensure the employee completed all mandatory fields including name, date of birth, attestation of citizenship or immigration status, and signature and date, noting any blank required fields as errors.

Verify that the employee's signature and the date the form was signed are present in Section 1, and that the date is on or before the first day of employment.

If someone other than the employee prepared Section 1 or translated documents, confirm the Preparer and/or Translator Certification block is completed with the preparer's name, address, signature, and date.

Verify that all I-9 forms on file use the currently valid version by checking the edition date in the lower left corner of the form, and plan to replace any outdated forms through the correction or re-verification process.

Verify that the employer representative examined acceptable documents and completed Section 2 of the I-9 within three business days of the employee's first day of employment for pay, or on the first day for employees hired for fewer than three days.

Ensure that the employer recorded either one document from List A (establishing both identity and employment authorization) or one document each from List B (identity) and List C (employment authorization) in Section 2.

Review each entry in Section 2 to confirm that document titles, issuing authorities, document numbers, and expiration dates are fully and accurately recorded for all presented documents.

Confirm that the employer accepted any valid combination of documents from the Lists of Acceptable Documents without requesting specific documents or more documents than required, which would constitute an unfair immigration-related employment practice.

Check that Section 2 includes the employer representative's signature, the date the documents were examined, the employer's name, and the employer's address, completed by someone who physically examined the original documents.

If a receipt for a replacement document was accepted, verify that the actual document was presented within 90 days and the I-9 was updated accordingly with the final document information.

Verify that Section 3 was completed on or before the expiration date of the employee's employment authorization, using a document from List A or List C showing the employee remains authorized to work.

Confirm that the employer did not reverify US citizens, non-citizen nationals, or lawful permanent residents, and did not reverify List B identity documents, as these do not require reverification under I-9 rules.

For employees rehired within three years of the original I-9 date, verify that Section 3 was completed with the rehire date and any updated employment authorization, or that a new I-9 was completed if the original was more than three years old.

If an employee's legal name changed, confirm that Section 3 Block A reflects the new name and that the change was recorded on the most recently completed I-9 for that employee.

Verify that each Section 3 entry includes the employer representative's signature and the date of reverification or rehire documentation, and that the same or a different authorized representative completed the section.

Verify that all I-9 forms are stored in a secure location, either in a separate I-9 file organized for easy retrieval during audits, or in an approved electronic storage system that meets DHS regulatory requirements.

Calculate the required retention period for each former employee's I-9 as the later of three years from the date of hire or one year after the date of termination, and mark forms for destruction once the retention period expires.

Securely destroy I-9 forms and any copies of supporting documents that are past the required retention period to reduce exposure in the event of a government audit, using shredding or other secure destruction methods.

If storing I-9 forms electronically, verify the system includes proper access controls, audit trails, backup and recovery procedures, and the ability to produce paper copies upon request, in compliance with 8 CFR 274a.2.

For errors found during the internal audit, draw a single line through the incorrect information, enter the correct information, and initial and date the correction, or attach a new Section 2 or 3 page with a note explaining the correction.

Ensure all corrections are dated with the current date of correction (not the original date), and that no liquid paper, erasure, or other methods that obscure the original entry are used on any I-9 form.

Create a detailed audit report listing all errors found, categorized by type (technical violations vs. substantive violations), corrections made, and any systemic issues identified that require process improvements.

Based on audit findings, provide targeted training to HR staff and hiring managers on proper I-9 procedures, including acceptable document review, anti-discrimination requirements, and E-Verify procedures if applicable.

Implement a recurring internal audit program, such as quarterly spot checks of new hires and annual comprehensive reviews, to identify and correct I-9 compliance issues proactively before a government notice of inspection.

Develop a written protocol for responding to a DHS or ICE Notice of Inspection, including designating a point of contact, engaging legal counsel, gathering I-9 forms within the three-day response window, and communicating with affected employees.