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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 critical (required)

Verify the audit list matches the active and terminated employee roster for the selected period.

Yes No N/A

Section 1 Employee Information Review

Employee name, address, date of birth, and attestation completed critical (required)

Confirm all required Section 1 fields are present and legible.

Yes No N/A

Employee attestation selected correctly critical (required)

Verify the employee selected the appropriate citizenship or immigration status attestation.

Yes No N/A

Employee signature and date present critical (required)

Confirm Section 1 is signed and dated by the employee or authorized preparer/translator where applicable.

Yes No N/A

Preparer/translator section completed when used

If a preparer or translator assisted, confirm the certification is completed and signed.

Yes No N/A

Section 2 Employer Review and Document Verification

Section 2 completed within required timeframe critical (required)

Confirm the employer completed Section 2 within 3 business days of the employee's first day of employment.

Yes No N/A

Document title, issuing authority, number, and expiration recorded accurately critical (required)

Verify the document information entered in Section 2 matches the original documents presented.

Yes No N/A

Employer representative signed and dated Section 2 critical (required)

Confirm the employer or authorized representative completed the certification and date fields.

Yes No N/A

Document combination appears acceptable for the form critical (required)

Check that the documents presented reasonably satisfy List A or List B and List C requirements without requesting prohibited documents.

Yes No N/A

Reverification and Rehire Review

Reverification required dates tracked critical (required)

Confirm employees with expiring work authorization are tracked before document expiration.

Yes No N/A

Reverification completed before authorization expiration critical (required)

Verify reverification was completed on or before the employee's authorization end date when required.

Yes No N/A

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.

Yes No N/A

Retention, Corrections, and Record Integrity

Retention rule applied correctly for active and terminated employees critical (required)

Verify each form is retained for the required period based on hire date and termination date rules.

Yes No N/A

Corrections made using proper audit trail method

Confirm corrections are initialed, dated, and explained without obscuring original entries.

Yes No N/A

Missing forms or supporting documents identified critical (required)

Flag any missing Form I-9s, missing pages, or absent supporting records for remediation.

Yes No N/A

Potential substantive or technical errors logged

Document any errors that may require legal review or correction before an inspection.

Yes No N/A

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 critical (required)

Indicate whether counsel or a qualified immigration compliance specialist should review the findings.

Yes No N/A

Inspector signature critical (required)

Signature confirming the audit review is complete and findings are accurate.

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Run: I-9 Internal Audit Checklist

Audit Setup and Scope

Section 1 Employee Information Review

Section 2 Employer Review and Document Verification

Reverification and Rehire Review

Retention, Corrections, and Record Integrity

Closeout and Corrective Actions

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