Sample I-9 Audit Checklist: Form I-9 Violations to Look for and Correct

This downloadable sample checklist provides a starting point to help you identify errors on the Form I-9 during a routine internal audit. How you choose to log said errors is up to you; some employers will use a spreadsheet-based chart for an audit, others mark errors on a separate cover sheet for each I-9 and also record in a centralized location.

HR professionals should undergo a refresher training before conducting any audit and should consult legal counsel to ensure that any review and remediation does not compound issues or expose their organization to liability. Additionally, HR representatives should consider working with an attorney for guidance and to establish attorney-client privilege for the audit where appropriate. Organizations with internal legal counsel should notify them before initiating an audit.

It is very important that the HR representative be familiar with U.S. Citizenship and Immigration Services’ (USCIS’) I-9 procedures, including terms and documents referenced in the catch-all “violations” list below. For example:

• Did you know not all Social Security cards are issued by the Social Security Administration, and thus, there are several different entities that could be listed under “issuing authority” for someone’s Social Security card?
• Do you know the difference between the USCIS number and alien number that must be provided in Section 1 of the Form I-9 for a licensed permanent resident (LPR)?

The more familiar you are with these documents, agencies, and regulations, the more easily you can spot discrepancies on a Form I-9.

Need a primer on the Form I-9? Start with this breakdown of who does — and does not — need to fill out the form.