Click link for more information: Form I-9 Internal Audit Checklist

Federal law requires employers to hire only individuals who may legally work in the United States—either
U.S. citizens or authorized foreign nationals. To comply with the law, employers must verify the identity
and employment authorization of each individual they hire by completing and retaining the Employment
Eligibility Verification form (Form I-9). Employers must have a completed Form I-9 for every employee
hired after Nov. 6, 1986.

Complying with Form I-9 requirements accurately and in a timely manner is difficult. The risk employers
face for any errors is real and can be extremely expensive. Employers that fail to comply with Form I-9
requirements can face severe consequences, including civil and criminal penalties.
Despite employers’ best efforts, compliance with Form I-9 requirements can be complex and is rarely
foolproof. Though they can be time-consuming and labor-intensive, internal audits can be a systematic
means for organizations to ensure compliance with federal law.

Overview

This checklist outlines the steps for conducting an internal audit of your organization’s Forms I-9. This
checklist is intended to be used as a guide, and not all of the following steps are necessary for an
organization’s internal audit. The audit process may differ based on your organization’s size and other
factors; thus, the steps in this list should be modified to meet the unique needs of your organization. This
checklist is to be completed by someone trained in Form I-9 requirements, such as an HR representative,
to help ensure a smooth audit process.

This checklist provides an overview of a Form I-9 internal audit and should not be construed as legal
advice. Due to the complex nature of Form I-9 compliance, employers are encouraged to seek legal
counsel to discuss and address specific issues and concerns.