Upcoming Increase in I-9 Audits: Is Your Business Prepared? (December 2025 TogetHR Times)

Federal agencies have indicated that Form I-9 audits are expected to increase in the coming months as part of a nationwide effort to strengthen immigration and employment eligibility enforcement. These audits are designed to verify that employers are properly completing and maintaining Form I-9 for every employee hired in the United States, as required by law. While most employers complete the form at the time of hire, many organizations are surprised to discover errors or inconsistencies later,issues that can lead to fines, penalties, or unnecessary stress during an audit.

If your company is selected for review, you will have only three business days to provide all I-9 documentation requested by federal authorities. That means there is little time to identify and correct errors, locate missing records, or organize files. Taking the time now to review your I-9 documentation will help you avoid last-minute scrambling and demonstrate a proactive commitment to compliance.

A good first step is to conduct an internal I-9 audit. Review each form to ensure that every section is fully completed, properly signed, and dated. Verify that the documents used to establish identity and employment authorization were valid at the time of hire and that any necessary reverifications have been handled correctly. If you identify errors, make corrections following federal guidelines, ensuring that changes are initialed and dated rather than rewritten or replaced.

It is also important to review how your I-9s are stored and maintained. Employers may keep I-9 forms on paper, electronically, or a combination of both, but all must be stored securely and separately from general personnel files. Retention rules require that employers keep I-9s for at least three years after the date of hire or one year after the employee’s separation, whichever is later. Once that period passes, documents may be safely purged to avoid unnecessary liability.

Beyond compliance, a regular I-9 review is a smart business practice. It helps ensure consistency across departments, reduces the risk of errors caused by turnover in HR or hiring roles, and reinforces accountability within the organization. A well-organized I-9 system also builds confidence if your business ever faces an audit or inspection.

If you would like help reviewing your I-9 files or guidance on how to structure an internal audit, our team is happy to assist. We can help you create checklists, update your processes, and train staff to maintain compliance going forward. Taking a proactive approach today can protect your organization from fines, save valuable time, and provide peace of mind in the months ahead.

By Joan Klopfer