Guides / Self-audit checklist

I-9 self-audit checklist for 2026

A self-audit is how you find the errors ICE fines before an inspection finds them. Here is the order to work in, what to look for on each form, and how federal guidance says to fix what you find.

I9Scan guide · Updated September 15, 2026 · Not legal advice

Already received a Notice of Inspection? Stop here and contact an immigration attorney. Don't change forms after a notice arrives without legal advice.

1. Decide which forms to review

• Review all forms, or choose a subset for neutral reasons, such as a location, a hiring date range or a department. ICE and the Justice Department's Immigrant and Employee Rights Section warn that choosing forms based on citizenship status or national origin can be discriminatory.
• Include former employees still inside the retention period. Inspections ask for them too.
• Don't audit selectively in response to a complaint or a union campaign. The same guidance warns against audits that are, or look, retaliatory.

2. Separate forms you must keep from forms you may discard

You must keep a Form I-9 for three years after the date of hire or one year after employment ends, whichever is later. Compare the two dates for each former employee: once the later date has passed, the form is no longer required.

Current employees' forms are always kept.

3. Check every required form exists

Compare a current payroll list and a list of terminated employees against your I-9 files. A missing form is a substantive violation, and no correction on other forms makes up for it.

4. Review each form, field by field

Section 1 (completed by the employee, no later than the first day of work)

• Legal last and first name substantive
• Date of birth substantive
• Exactly one citizenship or immigration status box checked substantive
• A-Number for a lawful permanent resident; expiration date (or N/A) plus A-Number, I-94 or foreign passport details for a noncitizen authorized to work substantive
• Employee signature and the date next to it substantive
• Signed no later than the first day of employment substantive
• Address, other last names used (or N/A) technical

Section 2 (completed by the employer within three business days of the first day)

• Document title, issuing authority, document number and expiration date for List A, or for both List B and List C substantive
• First day of employment substantive
• Employer representative's name and title substantive
• Employer signature and date substantive
• Completed within three business days of the first day of employment substantive
• Alternative procedure box checked if documents were examined remotely, and only if the employer uses E-Verify substantive
• Business name and address technical

For the reasons behind these labels, see ICE's March 2026 rule change.

5. Correct errors the way USCIS describes

• Section 1 errors are corrected by the employee, not by you. Ask the employee to make the correction.
• Section 2 and Supplement B errors may be corrected by the employer.
• How to correct: draw a single line through the incorrect information, write the correct information, then initial and date the correction.
• Date corrections with today's date. Never backdate, and don't use correction fluid. If correction fluid was used in the past, attach a signed and dated note explaining what happened.
• Complete a new Form I-9 when errors are major, for example a whole section left blank or Section 2 completed with unacceptable documents. Keep it with the original.
• Don't conceal changes. USCIS says not to hide corrections on the form.

6. Write a memo to file

USCIS recommends including a note explaining why you changed an existing form or completed a new one. A short audit memo is also worth keeping: when you audited, which forms, what you found, what you corrected and what you changed so new forms come out right.

7. Fix the process, not only the forms

• Give whoever completes Section 2 a one-page checklist of the substantive fields.
• Check each new hire's form within three business days, not at year end.
• Track work authorization expiration dates so reverification is on time.

Correcting forms before an inspection is permitted, but a correction does not guarantee that ICE will treat a form as compliant. Good faith is one of five factors ICE weighs when setting a fine. See how I-9 fines are calculated.