What’s New in 2025

ICE continues to ramp up its workplace enforcement efforts. This includes surprise audits, document requests, and investigations that target industries with high levels of employment-based risk. With more attention on documentation accuracy, employers must take ownership of their compliance practices.

Common I-9 Compliance Pitfalls

Even well-meaning businesses can slip up when it comes to I-9 forms. Here are a few mistakes we see often:

• Incomplete or inaccurate forms: Sections left blank, missing signatures, or incorrect dates.

   

• Improper storage: I-9s must be kept separate from personnel files and accessible for inspection.

   

• Lack of training: Managers unfamiliar with acceptable documents may unknowingly approve invalid forms.

   

How to Conduct an Internal I-9 Audit

A self-audit can help uncover risks and correct errors before ICE steps in. Here’s a simplified process:

1. Gather all I-9 forms (active and past employees still within the retention window).

    

2. Review for errors: Check each section for completeness and consistency.

    

3. Correct mistakes: Follow USCIS guidance for making clean corrections with initials and dates.

    

4. Separate and store properly: Keep current I-9s in one secure file and terminated employee forms in another.

    

Not sure what to look for? We recommend working with an HR professional to support your audit and avoid unintentional errors.

Train Your Managers and HR Staff

Compliance starts with informed teams. Make sure those responsible for onboarding and recordkeeping:

• Know which documents are acceptable

   

• Understand timing requirements for form completion

   

• Are trained to spot and document errors properly

   

Annual refresher training can go a long way in maintaining best practices.

I-9 compliance is more than a box to check. It’s a critical part of protecting your business and your workforce. Staying ahead of ICE audits means creating consistent processes, training your team, and addressing issues proactively.

Need help reviewing your I-9 process?
LFV Consulting offers hands-on compliance audits and tailored training for small and mid-sized businesses. Contact us today to make sure your documentation is in good shape.