Annual I-9 Audits: Why Your Company Isn’t One and Done

October 7, 2014

We try to always remind our current clients when it is time for their annual I-9 audit to help them maintain immigration compliance.  A lot of our clients understand why their business needs an initial I-9 audit to “clean up” their I-9s, but by the time a year has passed, they may not realize the importance of having their I-9s audited on an annual basis.

According to ICE Best Practices, businesses need to have a system in place to prevent errors on their I-9s.  As part of this compliance system, companies should be having ANNUAL I-9 audits on their company’s I-9 forms conducted by a trained I-9 auditor.  The I-9 audit serves a dual purpose:  it ensures that all the errors are caught and corrected before ICE gets involved and demonstrates to the government that the employer is serious about immigration compliance and is not simply “turning a blind eye”.

The initial I-9 audit includes a lot of training, corrections, and a small amount of blood, sweat, and tears (kidding, of course ).  However, what the client may not understand is the ease of the annual I-9 audit the second, third, fourth, etc. time around.  By the second I-9 audit, I-9 Administrators are already trained and instead of auditing their entire employee payroll, the audit is only on newly hired employees.  For example, if a company has 50 employees during the initial I-9 audit and only hires 5 employees the following year- the second annual I-9 audit will only be conducted on the 5 newly hired employees.  Easy peasy for a seasoned and well-trained I-9 Administrator!  The annual audit serves as a good check on the business’ I-9 Administration and remedies any errors/problems that may occur.  The 2014 annual audits proved to be especially helpful to our clients after the new version of the form was released in 2013.  Employers are able to see how they are correctly completing the new forms and what areas could use improvement, if any.

A recent case on an ICE audit can be found here.

More information on I-9 Administrator training can be found here.


Jessica Haefele
Corporate Immigration Attorney

7007 College Blvd., Ste. 460 | Overland Park, KS 66211
Phone  ::  913.317.6200    
Email  ::

Website  ::

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