I-9 Audit Checklist for Employers | Self-Audit Guide

An I-9 audit is a form-by-form check that every employee file is complete, correct and kept the right way. This checklist covers what to look at on each form, the process problems that cause repeat errors, and how to fix what you find without making things worse.

It follows the same standard an ICE inspector applies. For what changed in 2026 and how an inspection unfolds, read I-9 Audits in 2026: What an ICE Notice of Inspection Means.

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Our I-9 audit and compliance review covers up to 25 existing I-9 files for errors, for $199. You get a clear list of what needs correcting.

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Before you start

Decide who fixes what. Do not begin an audit you are not prepared to finish. Finding errors and leaving them uncorrected can hurt you more than not looking. See our audit post for why.
Gather one file per employee. Keep I-9s in their own binder or folder, apart from personnel files, so any form can be pulled quickly.
Include former employees. Forms must be kept after someone leaves. Use the I-9 retention calculator to see which forms you still have to hold.
Decide on sample or full. Checking every form is the safest. If you sample, check enough to be confident, and widen the review when you find a pattern.

Section 1: the employee’s part

The employee completes Section 1 no later than their first day of work. Check each form for:

Complete personal information. Full name, other last names used, address, date of birth, and any other required identifying number.
A citizenship or immigration status box checked. Exactly one status, with any required number or expiration date filled in.
A signature and date from the employee. The date must be filled in, and it must be on or before the first day of work.
Supplement A, if someone helped. If a preparer or translator assisted, their section must be complete.

Remember that you cannot fix Section 1 yourself. If it has an error, the employee must correct it.

Section 2: your part

You complete Section 2 within three business days of the employee’s first day of work. See the I-9 three-day rule for how the count works. Check for:

The right document combination. Either one document from List A, or one from List B plus one from List C. Not more, not fewer. See the full acceptable documents list.
Complete document data. For every document: title, issuing authority, document number and expiration date where one applies. Missing document data is a common and serious error.
The first day of employment. Entered correctly in the certification.
The representative’s details. Name, title, signature and date, plus the business name and address.
A timely date. Section 2 signed within three business days of the start date, not weeks later.
Documents the employee chose. You cannot require specific documents. Asking for a particular one can lead to a discrimination claim.

Section 3 and Supplement B: reverification

Only when work authorization expires. Reverification applies to employees whose work authorization has an expiration date. It does not apply to U.S. citizens or to permanent residents, and a green card expiring is not a reason to reverify.
Done on time. Use a tracker or calendar to catch expiration dates before they pass.
Filled in correctly. The date, new document information and signature are all present. See I-9 reverification and Supplement B.

The whole-process checks

Current form edition. As of August 1, 2026, employers must use the edition showing a 05/31/2027 expiration date. Check the edition in the bottom corner of each blank form.
Spanish form used outside Puerto Rico. The Spanish version may only be completed in Puerto Rico. Elsewhere it is a translation aid, and the English form must be filled in.
Remote document review. If anyone reviewed documents by video, confirm your company was enrolled in E-Verify at the time and that the alternative procedure box was checked. See online and remote I-9 verification.
Consistent copying. Either keep copies of documents for every employee or for none. Copying for some and not others looks like selective treatment.
A clean paper trail. No white-out, no erasing, no backdating, and no pencil.
Retention. Forms are kept three years after the date of hire or one year after employment ends, whichever is later. Do not destroy anything early.
Separate storage. I-9s are not in personnel files, and you can produce any one within hours.

How to correct an error

Draw a single line through the incorrect entry, write the correct information, then initial and date the change. Never use correction fluid, never erase, and never backdate. You may correct Section 2, Section 3 and Supplement B; an error in Section 1 must be corrected by the employee. If a form has many errors, complete a new one, attach it to the original, and add a signed and dated explanation of what you did and why.

Keep a short log of every correction. A record showing that you found problems and fixed them is evidence of good faith.

Fix the process, not just the form

When the same mistake appears on several forms, the cause is usually the process. Common fixes:

Give new hires Section 1 on or before the first day, not later.
Put a calendar reminder on the third business day.
Use a checklist at the desk when completing Section 2.
Track expiration dates in one place.
Have one trained person handle I-9s, or use an authorized representative who does it every day.

Frequently asked questions

How often should I audit my I-9s?

At least once a year, and any time you change who completes them, switch to a new system, or acquire another business.

Who can do an internal I-9 audit?

Anyone trained on the form. Because the stakes can be high, many employers have an immigration attorney or an outside I-9 reviewer check the results.

Should I fix mistakes before an ICE notice arrives?

Yes. Correcting errors before a notice is the strongest evidence of good faith. Fixes made after a notice carry much less weight.

Can I just redo old forms?

No. Do not throw away the original or backdate a new form. Correct the original, or attach a new form with a dated explanation.

How much does an I-9 audit cost?

Our review of up to 25 files is $199. Larger files and ongoing compliance are available on our monthly plans.

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I-9 Audit Checklist for Employers: What to Check on Every Form