HR Checklist

Helping to make the I-9 completion

process more seamless.
Completing Forms I-9 Three keys to
establishing a
with confidence. more seamless
There’s no question that onboarding a new employee requires a I-9 process:
large amount of time and effort. You want them to feel welcomed,
but there’s also the need to fill out I-9s accurately. With everything
on your plate, it’s easy for an occasional mistake to pass you by.
Create a procedures
1
manual for Forms I-9.

An estimated 76% of

76%
Hold yearly internal
paper I-9s are missing, 2
Forms I-9 training
incomplete, or have errors.1
sessions.
Your company is liable for I-9s in its possession.

Conduct regular
3
self-audits of Forms I-9.
Taking steps to meet I-9 regulations can help prevent problems,
better prepare you for a possible visit from the U.S. Immigration and
Customs Enforcement (ICE) and have a positive impact, including
helping mitigate fines, if an investigation finds any I-9 errors.

Whether you manage your company’s HR needs on your own or

you’re part of a large team, this document can help ensure you’re
following some of the best steps to help you in your I-9s while
helping you better maintain I-9 compliance. Let’s get started.

1
https://www.dhs.gov/sites/default/files/publications/fy_2021_dhs_bib_web_version.pdf

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STEP 1: CREATING THE PROCEDURES MANUAL

Stay more organized while

helping to avoid errors.
Giving Section 2 completers a thorough list of policies and procedures
to follow for I-9s will go a long way toward helping to prevent errors and
staying organized. While it doesn’t have to cover every potential situation,
make sure it contains the following information: When to start
the Form I-9
process
Your internal policies regarding Forms I-9

Describe all parties involved. Employees can complete Section 1

as soon as they receive a job offer.
Describe each party’s responsibilities.
Section 1 must be completed by
Define your communications process with employees regarding an employee’s first day.
Forms I-9.
Section 2 must be completed
How to manage I-9 completion for remote employees within three business days of the
or a dispersed workforce employee’s start date.

Include instructions for who can serve as a Section 2 completer. Demanding a specific type
of document when verifying
Consider using third-party agents or notary publics as options if or reverifying an employee’s
Form I-9 could be considered
no one from your company is local.
discriminatory. U.S. Citizenship
and Immigration Services (USCIS)
Consider developing a network of completers in key cities. offers other tips to help avoid
discrimination during the Form
How to manage special circumstances, such as when I-9 process.

employees rely on a visa to be authorized to work in the U.S.

Not all notaries are familiar
Counsel employers to accept any valid combination of with Forms I-9 needs. Notaries
identification and employment authorization documents. should complete Section 2 as an
authorized representative and not
as a notary.
How to escalate
Also, select states make notaries go
Create a path for especially challenging instances.
through specific Forms I-9 training.

How to handle reverifications

Reverifications are necessary when employment verification

documents have expired.

At least three months before their current documents expire, notify

affected employees that they will need to present new List A or
List C documents.

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STEP 2: TR AINING FOR SECTION 2 COMPLETERS

Help stay ahead of changes by keeping

yourself and/or your team sharp.
Since I-9 regulations change periodically, it’s important to keep Section 2
completers in the know to help ensure accuracy.

Ideally, your Section 2 completer training should:

Occur at least once per year to educate new personnel and advise Focus on situations known
existing Section 2 completers about annual changes. to be challenging for your
company, such as:
Require all Section 2 completers to attend.
An option is to record the training and require Section 2 completers to • Specific documentation

provide proof of attendance. • In-person inspection of

Section 2 documents

Review any updates to I-9 regulations or changes • Late submissions

to enforcement positions. • Communication issues
Stay updated, get best practices, and see the latest trends with I-9 • Starting the I-9 process earlier
updates from the team at Equifax Workforce Solutions.

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STEP 3: CONDUCTING A SELF-AUDIT

Keep compliance top of mind with tips for

conducting an internal audit.
When ICE audits a company, they typically give 72 hours’ notice, which isn’t much.
A self-audit helps you identify and correct problems before they become penalties.

Gather Forms I-9 (both paper and electronic).
Note how many, where they are stored, and
what format.
Purge the forms that no longer need to be
retained.
After an employee has left the company, you only
need to keep their forms for three years after
their date of hire or one year after their departure
(whichever is later).
You are liable for errors on any forms you retain,
even if you weren’t required to still have them
on file.
Identify issues with current forms.
Here is a list of common mistakes from USCIS.
Make corrections.
USCIS directions for how to complete and correct I-9s
can be found here.
Have employees make corrections to Section 1.
Have Section 2 completers make corrections to
Sections 2 and 3. (Note: If the original completer isn’t
available, another Section 2 completer can step in.)
Complete a new Form I-9 if multiple mistakes
necessitate (keep the original I-9 alongside it).

Identify missing forms. Maintain a detailed audit trail noting what

Make sure you have a Form I-9 for all changes were made, by whom, and, in some
current employees. cases, why they were made.

For more details on how to conduct a self-audit, check out

the Guidance for Employers Conducting Form I-9 Audits.

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Help finish your I-9s The benefits of
simplifying your
faster so you can focus I-9 process:
on your people. • Frees up time for more
meaningful interactions
Discover an automated management system that helps with employees
take the monotony out of I-9 completion.
• Improves the experience for new
hires unfamiliar with HR paperwork
Instead of getting knee-deep in paperwork, we can help you get
• Guides you through the process
back to doing what really matters: spending quality time with your
with step-by-step instructions
new hires. The award-winning I-9 Management, I-9 Anywhere®, I-9
Conversion, and I-9 Audit and Remediation services from Equifax • Offers clear and simple prompts
Workforce Solutions can help you streamline completion and that turn complex questions into
provide better accuracy. tasks that are easier to understand

• Keeps you on track to completion

with simple reminders

• Allows for monitoring progress

Click here to view a demo today! • Helps automate the

e-verify process

See how we can help you create an automated • Offers a centralized, user-friendly
and easier I-9 process. dashboard where all completed
forms are stored

• Helps protect the privacy of

your employees

Copyright © 2021, Equifax Inc., Atlanta, Georgia. All rights reserved.

Equifax and I-9 Anywhere are registered trademarks of Equifax Inc. 20-105093
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