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Form I-9 Self-Audit Checklist

Pull a Form I-9 and walk it line by line: Section 1, Supplement A, Section 2, Supplement B, then retention and storage, your electronic system and E-Verify if you use them. Mark each line, and every one that needs a fix shows how USCIS says to correct it, without backdating and without asking the employee for documents you may not request. Print the result for the file or copy it into your audit log. If an inspection notice is what sent you here, read Form I-9 penalties next.

Use the tool

32 of 40 checked, 3 fixes to make

See the findings

Pre-filled with an example: one Form I-9 for a warehouse hire who holds a Green Card, part audited. Mark each line as you read the form; a line marked “Needs a fix” shows how to correct it.

Before you start

3 of 3 checked

Set these up before you pull the first form.

  • You are auditing every Form I-9, or a sample picked by a neutral rule, never by citizenship status, national origin, or an unreliable tip.

    IER and ICE internal audit guidance, p. 1 and p. 5

  • Employees were told in writing that an internal audit is happening, its scope and reason, and whether it is independent or answers a government directive.

    IER and ICE internal audit guidance, p. 1

  • One written standard decides how every deficiency is handled, and each conversation with an employee is documented.

    IER and ICE internal audit guidance, p. 1

Section 1, the employee

7 of 7 checked

Only the employee, or their preparer or translator, corrects Section 1.

  • Full legal last and first name entered (“Unknown” in First Name for a person with one name), plus other last names used, if any.

    M-274 § 3.0

  • Current address and date of birth (mm/dd/yyyy) entered.

    M-274 § 3.0

  • Social Security number entered if you use E-Verify (voluntary otherwise), and nobody asked to see the card.

    M-274 § 3.0

  • Exactly one citizenship or immigration status box checked.

    M-274 § 3.0

  • A lawful permanent resident gave an A-Number or USCIS Number; a noncitizen authorized to work gave an expiration date (or N/A) and one of an A-Number, USCIS Number, I-94 number, or foreign passport number and country.

    M-274 § 3.0

    How to correct

    Ask the employee to draw a line through the wrong entry, write the correct or missing information, and initial and date the change. Only the employee, or their preparer or translator, may correct Section 1. Attach a written explanation. If the employee has left, attach a signed and dated statement naming the error and why it could not be corrected.

    M-274 § 9.0

  • Signed (or marked) and dated by the employee no later than the first day of employment, and not before the job offer was accepted.

    8 CFR 274a.2(b)(1)(i)(A); M-274 § 3.0

  • Nobody asked the employee for documents to back up what they wrote in Section 1.

    M-274 § 3.0

Supplement A, preparer and translator

2 of 2 checked

Only the preparer or translator, with the employee, corrects Supplement A.

  • Everyone who helped with Section 1 completed their own certification block in Supplement A, with a physical address (no P.O. box).

    M-274 § 3.0

  • The employee still signed or made their mark in Section 1, even with a preparer.

    M-274 § 3.0

Section 2, the employer

9 of 9 checked

Only you or your authorized representative corrects Section 2.

  • The form was a valid edition when it was completed. Today that is the 01/20/25 edition, or the 08/01/23 edition with the 05/31/2027 expiration date.

    uscis.gov/i-9, Edition Date

  • Documents examined and Section 2 completed within three business days after the first day of employment (Monday start, done by Thursday).

    8 CFR 274a.2(b)(1)(ii); M-274 § 4.0

  • One List A document, or one List B plus one List C document, each with title, issuing authority, number and expiration date (if any).

    M-274 § 4.0

  • The documents were acceptable under the Form I-9 rules in effect when the form was completed. Do not judge an old form by today's lists.

    IER and ICE internal audit guidance, p. 3

  • The employee chose the documents. Nothing shows you asked for a particular document or for more than the form requires.

    M-274 §§ 4.0 and 11.2

  • The employee's first day of employment entered.

    M-274 § 4.0

    How to correct

    Draw a line through the wrong entry, write the correct or missing information, and initial and date the change. Only you or your authorized representative may correct Section 2. Attach a written explanation. Never erase, never use correction fluid, never backdate.

    M-274 § 9.0

  • Signed and dated by the same person who examined the documents, with name, title, business name and a physical address (no P.O. box).

    M-274 § 4.0

  • Where a receipt was accepted, the replacement document was later recorded in Additional Information (a receipt for a lost, stolen or damaged document lasts 90 days).

    8 CFR 274a.2(b)(1)(vi); M-274 § 4.0

  • If documents were examined remotely, the alternative-procedure box is ticked, clear copies are kept, and the hiring site was in E-Verify in good standing.

    8 CFR 274a.2(b)(1)(ix); M-274 § 4.5

Supplement B, reverification and rehire

4 of 4 checked

Only you or your authorized representative corrects Supplement B.

  • Every employee whose work authorization expires was reverified on Supplement B no later than the expiration date.

    8 CFR 274a.2(b)(1)(vii); M-274 § 6.1

  • Nobody was reverified who never needs it: U.S. citizens, noncitizen nationals, or an expiring U.S. passport, passport card, Permanent Resident Card or List B document.

    M-274 § 6.0

  • Each Supplement B block has the employee's name from the original form, the document title, number and expiration date, and your name, signature and date, kept with the original form.

    M-274 § 6.1

  • A rehire within three years of the original form has a Supplement B block with the date of rehire, or a new Form I-9; a rehire after three years has a new Form I-9.

    M-274 § 6.2

Retention and storage

3 of 4 checked

File-level checks: run them once for the whole drawer or system.

  • A Form I-9 is on file for every current employee hired after November 6, 1986.

    M-274 § 10.0

  • No current employee's form was destroyed, and each former employee's form is kept until three years after hire or one year after employment ended, whichever is later.

    8 CFR 274a.2(b)(2)(i)(A)

  • If you copy employees' documents, you copy them for every employee, whatever their national origin or citizenship or immigration status, and keep the copies with the form.

    M-274 § 10.2

  • Every form, including any kept off-site, can be produced within three business days of an inspection notice.

    8 CFR 274a.2(b)(2)(ii); M-274 § 10.3

Electronic Form I-9 system

0 of 6 checked

System checks: ask your vendor for each one in writing.

  • The system has reasonable controls on integrity, accuracy and reliability, and controls that prevent and detect unauthorized or accidental creation, change or deletion of a form.

    8 CFR 274a.2(e)(1)

  • Every time a form is created, completed, changed or corrected, a secure, permanent record shows the date, who did it and what they did.

    8 CFR 274a.2(g)(1)(iv)

  • Only authorized personnel can open the records.

    8 CFR 274a.2(g)(1)(i)

  • You have written documentation of how forms are created, changed and kept, and how their authenticity is established, such as audit trails.

    8 CFR 274a.2(f)(1)(iii)

  • E-signatures capture an acknowledgment that the signer read the attestation, and the employee can get a printed confirmation on request.

    8 CFR 274a.2(h)(1)

  • You can give an inspector the hardware, software and staff to read and reproduce the forms and their audit trails.

    M-274 § 10.3

E-Verify, where you use it

4 of 5 checked

E-Verify checks: the case record lives in E-Verify, the form stays with you.

  • A case was created for each new hire no later than the third business day after they started work for pay.

    E-Verify User Manual § 1.5

  • No case was created before the job offer was accepted and the Form I-9 completed.

    E-Verify User Manual § 1.5

  • Every Tentative Nonconfirmation (Mismatch) was given to the employee in private with the Further Action Notice, and nobody was suspended, had pay cut or was let go while the case was open.

    E-Verify User Manual § 3.3

  • Each form carries its E-Verify case number, or you keep the Case Details page with it.

    M-274 §§ 4.0 and 10.3

    How to correct

    Write the E-Verify case number in the Additional Information space in Section 2.

    M-274 §§ 4.0 and 9.0

  • The Notice of E-Verify Participation and the Right to Work poster are displayed in English and Spanish, online too for remote staff.

    E-Verify User Manual § 1.5

Findings on this Form I-9

3 fixes to make

M-274 § 9.0; IER and ICE internal audit guidance

32 of 40 checked: 21 in order, 3 to fix, 8 not applicable.

  1. Section 1, the employee: A lawful permanent resident gave an A-Number or USCIS Number; a noncitizen authorized to work gave an expiration date (or N/A) and one of an A-Number, USCIS Number, I-94 number, or foreign passport number and country.How to correct: Ask the employee to draw a line through the wrong entry, write the correct or missing information, and initial and date the change. Only the employee, or their preparer or translator, may correct Section 1. Attach a written explanation. If the employee has left, attach a signed and dated statement naming the error and why it could not be corrected.M-274 § 9.0
  2. Section 2, the employer: The employee's first day of employment entered.How to correct: Draw a line through the wrong entry, write the correct or missing information, and initial and date the change. Only you or your authorized representative may correct Section 2. Attach a written explanation. Never erase, never use correction fluid, never backdate.M-274 § 9.0
  3. E-Verify, where you use it: Each form carries its E-Verify case number, or you keep the Case Details page with it.How to correct: Write the E-Verify case number in the Additional Information space in Section 2.M-274 §§ 4.0 and 9.0
The rule

This checklist applies the federal Form I-9 and E-Verify rules as written. It is not legal advice, and state law may add steps.

8 CFR 274a.2; M-274 § 9.0

Coloured pencil drawing of a clipboard with a sheet of empty boxes and a blue pencil
A clipboard of empty boxes waits for the first form.

What the checklist covers

It walks one Form I-9 in the order the form runs: Section 1, Supplement A, Section 2 and Supplement B, then the file-level checks on retention and storage, the system checks if you keep forms electronically, and the E-Verify checks if you use it. That is 40 lines in 8 groups, each with the rule it comes from. Mark a line “Needs a fix” and it shows the correction method from USCIS’s Handbook for Employers (M-274 § 9.0) or from the internal-audit guidance ICE and the Justice Department’s Immigrant and Employee Rights Section (IER) issued together.

The checklist does not date anything. For the Section 2 window use the I-9 and E-Verify deadline calculator, for a former employee’s purge date the I-9 retention calculator, for an expiring document the reverification calculator, and to test a document combination the acceptable documents checker. The full walk-through of each section is in the Form I-9 employer guide.

The rule

An internal audit is not required by law. It is how you find paperwork errors before an inspection does, but penalties can still be imposed after an internal audit, and the audit itself must not be discriminatory or retaliatory.

IER and ICE internal audit guidance, p. 1

How to correct a Form I-9

Who may touch a line depends on whose section it is. You never correct an employee’s Section 1 yourself, and an employee never corrects your Section 2. Every correction stays visible, carries initials and a date, and comes with a written note saying what changed and why.

Part of the formWho corrects itHow
Section 1The employee, or their preparer or translatorLine through the error, write the correct entry, initial and date it. If the employee has left, attach a signed and dated statement instead.
Supplement AThe preparer or translatorThe same, or have the employee correct it. A new preparer uses the next block and writes “for corrections”.
Section 2You or your authorized representativeLine through, correct, initial and date. A missing completion date gets today's date, initialled. Many errors: redo the section on a new form and attach it.
Supplement BYou or your authorized representativeLine through, correct, initial and date, with a written explanation.
Missing form or blank sectionThe employee for Section 1, you for Section 2Complete it now, enter the real first day of employment in Section 2, attach a signed and dated explanation.
Wrong editionYouStaple it to a blank current edition and sign that, or attach a note that it was filled out correctly in good faith.
Electronic formThe same people as on paperThe system's audit trail must show every correction and addition.
USCIS M-274 § 9.0 (Last Reviewed/Updated 07/18/2023); IER and ICE internal audit guidance, pp. 2-3.
Never

Never erase, never use correction fluid, never backdate. USCIS warns that concealing changes may lead to increased liability under federal immigration law. What a paperwork violation costs is set out in Form I-9 penalties.

M-274 § 9.0; IER and ICE internal audit guidance, p. 2

What an internal audit must not do

An audit done badly turns a paperwork problem into a discrimination problem. These are the lines ICE and IER drew in their joint guidance on internal Form I-9 audits.

  1. 01

    Choosing forms by who the employee is

    Audits should not be run on the basis of citizenship status or national origin, or in retaliation. Audit every form, or a sample picked by neutral criteria.

    IER and ICE internal audit guidance, p. 1

  2. 02

    Asking for particular documents

    You may say the questioned document cannot be used again; the employee still chooses which other acceptable documents to present.

    IER and ICE internal audit guidance, p. 3

  3. 03

    Re-asking because a photocopy is unclear

    An employer should not request documentation solely because photocopies of documents are unclear, and may not conclude without foundation that a copy is not genuine.

    IER and ICE internal audit guidance, p. 3

  4. 04

    Collecting new forms from everyone

    Outside an acquisition or merger, new Forms I-9 for all existing employees, without a deficiency or a systematic problem behind it, may raise discrimination concerns.

    IER and ICE internal audit guidance, p. 4

  5. 05

    Setting a 10-day or 90-day deadline as if it were law

    The 90-day no-match safe harbor was rescinded and ICE's 10-day period applies only after a Notice of Suspect Documents. Give a reasonable time, decided case by case; some documents take 120 days or more to obtain.

    IER and ICE internal audit guidance, pp. 4-5

  6. 06

    Acting on an anonymous tip

    Tips with no indicia of reliability, such as unsubstantiated, retaliatory or anonymous ones, are not a basis for heightened scrutiny of one employee's form.

    IER and ICE internal audit guidance, p. 5

  7. 07

    Running names through SSNVS

    The Social Security Number Verification Service is for wage reporting, not for checking employment authorization during an audit.

    IER and ICE internal audit guidance, p. 6

  8. 08

    Assuming an outside auditor carries the risk

    You may hand the audit to a third party, but you remain liable for any violation it commits.

    IER and ICE internal audit guidance, p. 5

What to do

  1. Tell employees in writing before you start, and pick the forms by a neutral rule.
  2. Tell an affected employee about a deficiency in private, with copies of their form.
  3. Correct in the open: line through, initial, date, attach a signed explanation.
  4. Let the employee choose the documents, and give a reasonable time to bring them.

Worked example

The checklist opens on this audit: one Form I-9 for a warehouse hire who presented a Permanent Resident Card, at an employer that uses E-Verify and an electronic I-9 system. Three lines need a fix; the electronic-system lines and two others are still open.

LineFindingCorrection
Section 1, status numbers“Lawful permanent resident” checked, A-Number blankThe employee writes the A-Number or USCIS Number, initials and dates it; you attach a short note.
Section 2, first dayFirst day of employment blankYou write the first day, initial and date the entry, and attach a note.
E-Verify, case numberCase created on day two, number not on the formWrite the E-Verify case number in Additional Information, or keep the Case Details page with the form.
Supplement BDoes not applyA Permanent Resident Card never triggers reverification.
Corrections per M-274 §§ 4.0, 6.0 and 9.0. No line is backdated and nothing is erased.

None of the three changes the hire. They are the kind of technical gaps the paperwork rules cover, which is why finding them yourself is worth the afternoon; the I-9 penalties guide explains how a good-faith attempt and a prompt correction weigh in an inspection.

State notes

  • Federal

Form I-9 and its corrections are federal, so the checklist is the same in every state. What a state can change is whether you must use E-Verify; check yours in E-Verify requirements by state, and read E-Verify for employers before you switch the E-Verify checks on.

If you examine documents over video, the remote I-9 alternative procedure sets the extra steps the Section 2 line checks for. If the electronic checks leave gaps, the I-9 software we compared lists what each vendor says about audit trails and storage.

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