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I-9 Audit Checklist: Everything You Need to Know

September 30, 2021 - minute read

It is important for employers to complete their I-9 forms properly for each employee they hire under the Immigration Reform and Control Act (IRCA) of 1986. Employers can face criminal punishment if the I-9 forms defy verification and employment eligibility requirements.

To prevent any mistakes in your I-9 forms, it is helpful to regularly conduct an I-9 audit internally. Below is our I-9 audit checklist to help you conduct the audit seamlessly and ensure that you don’t forget anything during the process.

What You’ll Need

In order to perform your I-19 audit correctly and thoroughly, you’ll need the following:

  • List of current employees
  • List of employees that were terminated in the past three years
  • Copies of all I-9 forms (either original or electronic)
  • Current I-9 form requirements
  • Up-to-date version of the USCIS’s Form I-9 M-247 Handbook for Employers

I-9 Audit Checklist Steps

1. Employee Information

First, ensure that you have the following information available for each employee and check to see if it is correct:

  • Employee first and last names
  • N/A for “Other Names Used” if it is not applicable
  • Maiden name or other names if it applies
  • Full address (excluding PO boxes)
  • Date of birth in mm/dd/yyyy format.
  • Social Security number (this is mandatory for E-Verify participants)

2. Citizenship or Immigration Status

Check to see that the following information regarding citizenship or immigration status is correct and competed:

  • Status (Make sure only one is selected)
    • Lawful Permanent Resident: make sure the alien registration number is included
    • An Alien Authorized to Work: ensure the work until date, alien number or admission number is correct
  • Expiration date of employment authorization

3. Employee’s Attestation

Next, you’ll want to review your employee’s attestation. Ensure these next items are complete and accurate:

  • Employee’s signature
  • Date of employee’s execution of form
  • Date of employees first day

* I-9 must be signed within 3 days of start3

4. Identity and Employment Eligibility Provided Documents (List A)

Ensure you have the appropriate information regarding identity and employment eligibility as well:

  • Correct document listed
  • List A document title
  • List A document issuing authority
  • List A document number
  • List A document expiration date
  • Receipt showing accepted application for document

5. Identity (List B)

For List B, ensure the following are complete and accurate:

  • List B document title
  • List B document issuing authority
  • List B document number
  • List B document expiration date if applicable
  • Receipt showing accepted application for document

6. Employment Authorization (List C)

For List C, ensure the following are complete and accurate:

  • List C document title
  • List C document issuing authority
  • List C document number
  • List C document expiration date if applicable
  • Receipt showing accepted application for document

7. Employer's Certification Information

Next, review your employer’s certification information by checking the following for accuracy and completion:

  • Employee’s first day of employment in mm/dd/yyyy format
  • Signature of Employer/Authorized Representative in the correct box
  • Date of certification in mm/dd/yyyy format
  • Certification signed within three days of hire
  • Title of Authorized Representative
  • Last Name and First Name of Authorized Representative
  • Employer’s Business or Organization Name
  • Address of business (No P.O. boxes are allowed)

8. Reverification Requirements

The only instance reverification is applicable is if employment authorization evidence presented in Section 2 becomes expired. You do not need to reverify US citizens, noncitizen nationals, or Lawful Permanent Residents.

However, if reverification is necessary, check for completion and accuracy of the following items:

  • Date of rehire in mm/dd/yyyy format if applicable
  • New name listed if applicable
  • Document title
  • Document number
  • Employment authorization document
  • Expiration Date in mm/dd/yyyy format
  • Signature of Authorized Representative present
  • Date of company certification in mm/dd/yyyy format
  • Printed name of Authorized Representative

What To Do About Missing I-9’s

Protocol for missing I-9’s differs between current and former employees. For current employees, have your employee present the appropriate documentation and complete an I-9, filling it out with the current dates. Then, attach a note explaining why there is a discrepancy between the hiring date and the I-9 form completion date.

For former employees, date and attach a note to an I-9 form for former employees, filling out any missing or incorrect information. Then, put the form with your other I-9 forms.

What To Do with I-9s with Errors

If the errors are easily correctable, you can correct these errors directly on the form. Cross out the incorrect information in a contrasting color of ink and put the correct information next to it. Initial and date next to each correction. If the errors cannot be corrected easily, you must complete a new I-9 form. Attach this new form to the new one with a note that explains why you are filling out a new form. Make sure to not throw away the old form.

How to Store I-9’s

Keep your I-9 forms separate from employee personnel files. It is strongly recommended to store your I-9 forms both electronically and in the form of a hard copy. Ensure that these files are only able to be accessed by a few HR representatives.

EPAY Can Help Improve Your HR Department’s Efficiency

From our human management software to our helpful human resources-related tips, EPAY is here to help your human resources department run more smoothly. For more information on proper I-9 practices or if you have other HR-related questions, please contact our team at EPAY today.

Filed Under: Compliance Human Resources