Section 1 of 6

Retention Compliance

Before You Begin
Generate a report listing all active employees, including employees on temporary leave of absence
Generate a report listing all termed employees with a hire date within the last four years
Generate a report listing all termed employees with a termination date within the last 12 months
Add a column to note whether a Form I-9 is on file
Add a column to note whether the correct revision of the Form I-9 is on file
You're ready to begin Section 1.
I-9 Form is on file for every active employee, with the correct version
Corrective Action
Replace forms and retrain hiring administrators. Conduct a retroactive I-9 audit to identify and document all missing or outdated forms.
I-9 Form is on file for termed employees with a hire date within the last three years and within one year of term date
Corrective Action
Conduct a retroactive I-9 audit for all termed employees within the retention window. Document gaps and corrective steps taken.
I-9 Forms are purged for termed employees with a hire date more than three years ago and a term date more than one year ago
Corrective Action
Establish a formal purge schedule aligned with the retention formula: 3 years from hire OR 1 year from termination, whichever is later.
Your Risk Indicator
High Risk — Missing Forms
Moderate Risk — Using outdated forms beyond allowed period
Compliant — Current version in use
Section 2 of 6

Form Completion & Accuracy

Before You Begin
Add a column to your existing worksheet to note what correction(s) is needed, when applicable
Designate a safe location to set forms aside that need a correction
You're ready to begin Section 2.
Section 1 is completed on or before employee's first day of work
Corrective Action
Implement a standardized onboarding checklist that includes Section 1 completion as a Day 1 requirement. Correct late forms using DHS guidelines — initial and date all corrections, no white-out.
Section 2 is completed within 3 business days of start date
Corrective Action
Document and correct late completions per DHS guidelines. Train employer representatives on the 3-business-day requirement. Add to onboarding tracking system.
All required fields are complete (no blanks, proper N/A usage)
Corrective Action
Correct technical errors per DHS guidelines. Use a standardized completion guide that clarifies when N/A is appropriate vs. required fields.
Employee signature and date are present and accurate
Corrective Action
Missing signatures on Section 1 cannot be corrected retroactively by the employee without explanation. Consult DHS guidance on handling unsigned forms. Do not backdate.
Employer representative signature and date completed within 3 business days of start date
Corrective Action
Correct per DHS guidelines. Clarify ownership of Section 2 completion responsibility in your onboarding process. Assign a specific designee per location or department.
No backdating or improper corrections identified
Corrective Action
Backdating is a substantive violation and a serious audit finding. Train all personnel on proper correction methods: single line through the error, correct information, initial and date. Never use white-out.
E-Verify case documentation (case details/results) is retained with the Form I-9 where applicable
Corrective Action
Establish a process to print and attach E-Verify case results to the corresponding I-9 at the time of completion. Conduct a retrospective review for any gaps in existing files.
Your Risk Indicator
High Risk — Incomplete sections, missing signatures, or late completion of Sections 1 or 2
Moderate Risk — Minor errors (missing fields, inconsistent N/A usage)
Compliant — Forms completed timely, accurately, and consistently
Section 3 of 6

Document Verification

Acceptable documents reviewed from List A OR List B & C
Corrective Action
Standardize document verification procedures. Provide all hiring administrators with the current USCIS List of Acceptable Documents and train on proper List A vs. B & C usage.
Documents appear genuine and relate to the employee
Corrective Action
Train hiring administrators on document examination standards. All documents must be reviewed in person (or via live video for remote hires per USCIS guidelines). Document the review process.
No over-documentation (only required documents retained)
Corrective Action
Eliminate over-documentation practices immediately. Requesting more documents than required is a form of discrimination under IRCA. Train all personnel: one List A OR one List B plus one List C — no more.
Consistency in document review practices across locations
Corrective Action
Perform spot audits across locations to identify inconsistencies. Standardize the review process with a written procedure and train all hiring managers uniformly.
Reverification completed timely where applicable (Section 3)
Corrective Action
Implement a tracking system for expiring work authorization documents. Reverification must be initiated before expiration — build in a 90-day advance reminder process.
Your Risk Indicator
High Risk — Improper document acceptance, over-documentation, or lack of verification consistency
Moderate Risk — Inconsistent practices across locations or hiring managers
Compliant — Consistent, compliant document review practices aligned with List A, B, C
Section 4 of 6

Policy, Training & Accountability

Written Form I-9 compliance policy is documented, current, and aligned with DHS requirements
Corrective Action
Develop or refresh a written I-9 compliance policy aligned with current DHS requirements. Include procedures for completion, correction, reverification, and retention. Have legal review it before distribution.
Designated personnel are clearly assigned responsibility for I-9 completion, review, and retention
Corrective Action
Clarify ownership in writing. Assign a primary owner and a backup per location or department. Include accountability in job descriptions and performance expectations.
Formal training on I-9 requirements and timelines has been provided to those responsible for onboarding
Corrective Action
Provide formal training for everyone responsible for I-9 completion. Document who was trained and when. Retrain whenever requirements change or personnel change.
Non-discriminatory processes are in place to ensure consistent application of I-9 procedures across locations
Corrective Action
Reinforce anti-discrimination requirements in all document review training. The same process must apply to every new hire regardless of national origin or citizenship status. Document that the process is applied uniformly.
Your Risk Indicator
High Risk — No written policy, limited training, or unclear accountability for I-9 compliance
Moderate Risk — Policy exists but training is inconsistent or ownership is not clearly defined
Compliant — Written policy, trained personnel, and clear accountability are in place
Section 5 of 6

Internal Audit & Corrections

Completed in the last 12 months

Errors were corrected using compliant methods (no white-out, with proper initial/dates)
Corrective Action
Standardize correction procedures: single line through the error, write the correct information, initial and date. No white-out, no backdating. Document the correction process in your compliance policy.
Documentation of audit findings and corrective actions was maintained
Corrective Action
Document audit findings and remediation steps going forward. Create a standardized audit log template that records what was found, what was corrected, by whom, and when.
A consistent audit process was applied across all business units/locations
Corrective Action
Establish a formal I-9 audit schedule (annual or semi-annual) and assign ownership for ongoing compliance monitoring. Use the same process across every location.
Your Risk Indicator
High Risk — No formal I-9 audit process; errors uncorrected or corrected improperly
Moderate Risk — Inconsistent or informal audits; limited documentation or corrections
Compliant — Routine, documented audits with proper correction methodology
Section 6 of 6

Storage & Recordkeeping

Stored digitally or paper, separate from employee records
Corrective Action
Separate I-9s from personnel files immediately. Storing them together is one of the most common ICE audit findings. Create a dedicated I-9 binder, folder, or electronic system that is distinct from the employee personnel file.
Secure and confidential storage (paper or electronic system)
Corrective Action
Centralize storage in a secure, access-controlled location. For electronic systems, ensure role-based access controls limit who can view and edit. Evaluate or upgrade your electronic I-9 system if it lacks audit trail functionality.
Organized for immediate retrieval (within three business days)
Corrective Action
Implement a retrieval protocol that allows production of any I-9 within 3 business days of an ICE request. Test the system: how long does it actually take to pull all I-9s without exposing other employee records?
Audit trail functionality enabled for electronic records
Corrective Action
Ensure your electronic I-9 system captures an audit trail of all entries and changes. If it does not, evaluate a compliant electronic I-9 system that meets DHS electronic records requirements.
Your Risk Indicator
High Risk — Stored with personnel files, disorganized, or not timely retrievable
Moderate Risk — Partial organization; inconsistent storage methods (paper vs. electronic)
Compliant — Secure, centralized storage with rapid retrieval capability
Overall Compliance Score
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Section Breakdown