I-9 Internal Audit Checklist

Inspection template for auditing Form I-9 records for completeness, accuracy, retention, and correction readiness before an internal review or ICE Notice of Inspection.

Audit Setup and Scope

• Audit population and sample scope documented
  Record the employee group, date range, and whether this is a full-file audit or a sample review.
• Audit date and reviewer identified
  Capture the audit date and the name or role of the reviewer performing the inspection.
• Reference policy or audit SOP attached
  Document the internal policy, SOP, or legal guidance used for the review.
• Employee file list reconciled to HR roster
  Verify the audit list matches the active and terminated employee roster for the selected period.

Section 1 Employee Information Review

• Employee name, address, date of birth, and attestation completed
  Confirm all required Section 1 fields are present and legible.
• Employee attestation selected correctly
  Verify the employee selected the appropriate citizenship or immigration status attestation.
• Employee signature and date present
  Confirm Section 1 is signed and dated by the employee or authorized preparer/translator where applicable.
• Preparer/translator section completed when used
  If a preparer or translator assisted, confirm the certification is completed and signed.

Section 2 Employer Review and Document Verification

• Section 2 completed within required timeframe
  Confirm the employer completed Section 2 within 3 business days of the employee's first day of employment.
• Document title, issuing authority, number, and expiration recorded accurately
  Verify the document information entered in Section 2 matches the original documents presented.
• Employer representative signed and dated Section 2
  Confirm the employer or authorized representative completed the certification and date fields.
• Document combination appears acceptable for the form
  Check that the documents presented reasonably satisfy List A or List B and List C requirements without requesting prohibited documents.

Reverification and Rehire Review

• Reverification required dates tracked
  Confirm employees with expiring work authorization are tracked before document expiration.
• Reverification completed before authorization expiration
  Verify reverification was completed on or before the employee's authorization end date when required.
• Rehire documentation linked to prior Form I-9
  Confirm rehires were matched to the original Form I-9 or a new form was completed when required.

Retention, Corrections, and Record Integrity

• Retention rule applied correctly for active and terminated employees
  Verify each form is retained for the required period based on hire date and termination date rules.
• Corrections made using proper audit trail method
  Confirm corrections are initialed, dated, and explained without obscuring original entries.
• Missing forms or supporting documents identified
  Flag any missing Form I-9s, missing pages, or absent supporting records for remediation.
• Potential substantive or technical errors logged
  Document any errors that may require legal review or correction before an inspection.

Closeout and Corrective Actions

• Deficiencies summarized with employee identifiers
  List each deficiency by employee record reference and brief issue description.
• Corrective action owner and due date assigned
  Document who is responsible for remediation and the target completion date.
• Legal review required for high-risk findings
  Indicate whether counsel or a qualified immigration compliance specialist should review the findings.
• Inspector signature
  Signature confirming the audit review is complete and findings are accurate.