How do I do a Forms I-9 self-audit?

It is a best practice to regularly self-audit completed Forms I-9.

Before performing the audit, decide the scope of your review. Will you review all forms or a sample? If auditing a sample, make sure your selection is random; otherwise, you may face claims of discriminatory audits.

Key areas to review in Section 1 of the Form I-9:

• Was the employee’s status entered correctly, and did those who identified their status as “lawful permanent resident” or “alien authorized to work” correctly enter the applicable document numbers?
• Did the employee sign and date the form?
• Did the employee complete the “Preparer and/or Translator Certification”?
• If a preparer or translator assisted the employee, did the preparer/translator complete the attestation?

In reviewing Sections 2 and Supplement B of the Form I-9, ask:

• Was the documentation from List A OR from Lists B AND C entered with the correct document title, issuing authority, document number and expiration date?
• Was the first day of employment correctly entered, and does it match the company’s payroll records?
• Did an agent of the employer sign the certification?
• Was the name, address and title of the business correctly entered?

If you find errors or omissions in Section 1, only the employee can correct them. You should notify the affected employee privately if they still work with you and ask them to correct the error by:

• Drawing a line through the incorrect information;
• Entering the correct or omitted information; and
• Initialing and dating the correction or omitted information.

A signed and dated employer-prepared statement should be attached to the corrected form explaining the modifications, such as “Company performed an internal audit and discovered that the form was not correctly completed at the time the employee was hired.”

If the employee is no longer working, the employer should attach to the Form I-9 a signed and dated statement identifying the errors and noting that the employee is unavailable to make the corrections.

A similar process is followed if corrections are required by a Preparer/Translator who helped with Section 1. The preparer/translator draws lines through incorrect information, enters correct information, and initials and dates corrections, and an employer-prepared explanatory statement is attached to the corrected form.

Only employers can correct errors and omissions on Sections 2 and Supplement B, and the same method is used.

If there are multiple errors and/or omissions in any of the sections, a new Form I-9 may be created and attached to the old form. Again, a written explanation should be attached describing why a new Form I-9 was created.

Keep in mind:

• If you failed to enter the date you originally completed Sections 2 or Supplement B, do not back date the form. Instead, enter the current date in the date field and initial it.
• Do not conceal any changes made on the Form I-9, such as by erasing text or using correction fluid.
• If you cannot locate a current employee’s Form I-9, complete the current version of the form as soon as possible. Use the date of hire and do not backdate the form. The employer should attach a signed and dated explanation of the corrective action taken.

Self-audits and corrections are important. Employers may be subject to penalties for violations.

Read more about Completing the Form I-9 in the HR Library.