Checklist: I-9 Audit

General  Instructions:

Employers must have an I-9 on file for every active employee hired after November 6, 1986.

Employers must have an I-9 on file for terminated employees for three years following date of hire or one year following date of termination—whichever is later.

The current version of the I-9 form as of the date of hire or reverification must be used.

Items Needed for Audit:

☐ List of current employees hired since November 6, 1986.

☐ List of employees terminated in the past three years.

☐ Original or electronic copies of all I-9 forms (both current employee forms, as well as forms for terminated employees within current retention requirements).

☐ Handbook for Employers M-274 published by the USCIS (optional)

☐ Current version of Form I-9

☐ Audit Log 

☐ I-9 Audit How-to Guide

Review I-9 Forms by Section:

Section 1

☐ Name (Including other last names used, past or present), address and date of birth are completed.

☐ Social Security number is entered if employer participates in the E-Verify program.

☐ Appropriate citizen/immigration status box is checked.

☐ Lawful permanent residents have provided their seven- to nine-digit Alien Registration Number (A-Number) or USCIS Number.

☐ Aliens have provided an Alien Registration Number/USCIS Number or Form I-94 Admission Number or Foreign Passport Number.

☐ Employee signed and dated the form no later than the first day of employment.

☐ Preparer or translator section is completed if someone other than the employee completed Section 1 on behalf of the employee.

Section 2

☐ Employee's name is entered as it appears in Section 1.

☐ The number is entered that correlates with the citizenship or immigration status box the employee selected in Section 1.

☐ One document from List A is listed and completed, or a combination of one document EACH from List B and List C are listed and completed.

☐ Documents have been entered into the correct section (e.g., List B item is, in fact, listed under list B and not List C or List A).

☐ If photocopies of documents are kept, copies of documents are maintained for all employees.

☐ The employee's first day of employment is entered.

☐ All information in the certification section has been entered and a representative of the company has signed and printed his or her name and dated the form within three days of the employee's first day of employment.

☐ The business name and full address are entered.

Section 3

☐ Section 3 is completed if the employee's work authorization expired or if the employee was rehired within three years from the date the I-9 form was previously completed.

☐ If the employee's name changed, the new name is entered in block A.

Correct Errors:

Section 1 Errors

If the employer discovers an error in Section 1 of an employee's Form I-9, the employer should have the employee correct the error as follows:

☐ Draw a line through the incorrect information. Do not use correction fluid or black out any information.

☐ Enter the correct information.

☐ Initial and date the correction.

Employees needing assistance to correct Section 1 can have a preparer and/or translator help with the correction. The preparer and/or translator should:                                                                                                  

☐ Make the correction or help the employee make the correction by drawing a line through the incorrect information and entering the correction information.

☐ Have the employee initial and date the correction.

☐ Initial and date the correction next to the employee's initials.

Section 2 and 3 Errors

When correcting Section 2 or 3, the employer should:

☐ Draw a line through the incorrect information. Do not use correction fluid or black out any information.

☐ Enter the correct information.

☐ Initial and date the correction.

Multiple Recording Errors

☐ Complete the section containing errors on a new I-9 form.

☐ Ensure the current version of the I-9 form is used.

☐ Attach the new I-9 form to the original I-9 form.

☐ Attach an explanation describing why the employer made the changes and completed a new form.

Missing I-9 Forms

☐ Have the employee complete section 1 of the current version of the I-9 form immediately.

☐ Inspect the employee's original documents and complete Section 2.

☐ Use current dates; do not backdate the form except that the employee's original hire date should be entered in Section 2.

☐ Do not continue to employ individuals who are unable to provide acceptable documents as required.

☐ Do not re-create the I-9 form without the employee's presence or without examining the employee's original documents.

☐ Do not re-create the I-9 form for terminated employees; rather, complete a note to file with an explanation.

Complete the Audit Log Entry and File the Corrected Form I-9:

☐ Complete the audit log of the I-9 forms containing errors.

☐ File the I-9 form in proper I-9 file (either current employee or terminated employee).