I-9

I-9 compliance faced a seismic shift last year. With new federal enforcement efforts, AI-driven audits, and increased scrutiny from ICE and USCIS, HR professionals must adopt smarter, faster, and more consistent practices to avoid fines and protect their workforce. This blog highlights key takeaways from Experian Employer Services’ recent I-9 compliance webinar and offers actionable insights to prepare your team for what lies ahead. I-9 compliance isn’t just about checking boxes anymore—it’s about protecting your business from legal, financial, and reputational risk. In this webinar, “I-9 Updates: Compliance, Audits & Enforcement,” I-9 experts André Gorash and Vijay Thakkar pulled back the curtain on this high-stakes topic. With over a decade of combined experience, André and Vijay highlighted major regulatory updates, shared real audit cases, and offered best practices for staying compliant in the face of growing enforcement and technological oversight. Want a deeper dive? Watch the full on-demand webinar “2025 I-9 Updates: Compliance, Audits & Enforcement” to get expert insights, real-world case studies, and practical tools your HR and compliance teams can use right away. Whether you're managing seasonal hires or navigating an internal audit, this session arms you with the knowledge to stay ahead of regulatory changes. Access the webinar replay here. AI + Audits = Zero Margin for Error The federal government is now leveraging a powerful AI system called RAVEN (Repository of Analytics in Virtualized Environment) to analyze I-9s, payroll records, audit trails, and more. This system uses OCR and machine learning to detect even minor I-9 errors—turning small clerical oversights into audit triggers. ICE’s enforcement arm is also growing, with the number of agents expected to increase from 6,000 to 16,000 by 2029. Surprise audits and site visits are becoming more frequent, especially in industries like hospitality, healthcare, agriculture, retail, and manufacturing. The Real Cost of I-9 Mistakes Recent enforcement actions have resulted in multimillion-dollar penalties. For example, three janitorial service companies in Denver were fined over $8 million combined. One company received a $6 million fine for knowingly employing 87 unauthorized workers. Even companies without malicious intent—just missing reverification deadlines—were heavily penalized. Civil fines range from $288 to $28,000 per violation, and errors related to employment authorization can escalate rapidly. Compliance Hot Spots in 2025 Several updates are catching employers off guard: DACA (C33) renewals are reopening. Be prepared to see more employees presenting valid work authorization under this category. TPS expirations for Syria and South Sudan mean affected employees must provide alternative documentation by early 2026. FNU/LNU IDs (First/Last Name Unknown) do not always indicate fraud and can result from cultural or processing inconsistencies. Handle these with care and awareness. Seasonal Hiring Pitfalls Seasonal employees hired for less than three business days must complete both Section 1 and Section 2 of the I-9 on their first day—the typical three-day grace period does not apply. Employers must also close out TNCs in E-Verify if the employee leaves before the issue is resolved. Rehiring someone? While it’s legally acceptable to reuse their original I-9 via Supplement B, best practice is to complete a new I-9 every time. This ensures you're aware of any status changes or revoked EADs that may have occurred since their last hire. Internal Audits: Don’t Wait for ICE Internal I-9 audits are the most effective defense against penalties. Start by gathering all I-9s for current and recently terminated employees. Review them using the USCIS M-274 Handbook, verify you're using the correct form version, and document all corrections with detailed memos to show good faith efforts. Important tips: Apply the same I-9 procedures across all job levels to avoid discrimination. Prepare for federal scrutiny before you receive a Notice of Inspection. Maintain a clean, auditable trail using a centralized electronic system. Choosing the Right I-9 System When evaluating an electronic I-9 solution, look for: Compliance features and automation Intuitive user experience Real-time alerts and reporting Auditability and fast record access Seamless E-Verify integration Scalability for future growth Dedicated support for policy updates An electronic system reduces human error and enforces consistent workflows—especially critical for distributed or seasonal teams. Key Takeaways AI is driving new enforcement. The RAVEN system ensures even minor mistakes are found. Fines are real—and rising. Noncompliance penalties can exceed $28,000 per violation. Seasonal and rehires require special care. Always verify documentation properly and complete new I-9s when needed. Consistency matters. Apply your I-9 process equally to all staff, from executives to hourly workers. Electronic systems simplify compliance. Invest in tools that reduce risk and provide audit-ready documentation. Start internal audits now. Don’t wait for an official request to uncover compliance gaps. For more tools and thought leadership on workforce compliance, visit the Experian Employer Services Blog.

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