In 2025, new federal leadership brought a sharp shift in enforcement priorities at U.S. Immigration and Customs Enforcement (ICE).
Most notably, American businesses are experiencing a resurgence in worksite inspections, including an increase in Form I-9 audits. With thousands of audits projected in the coming months, companies are once again under intense federal scrutiny.
Form I-9, mandated by the Immigration Reform and Control Act (IRCA), requires all employers to verify the identity and employment eligibility of every new hire, regardless of citizenship status. In today’s enforcement environment, I-9 management is risk management—and the cost of getting it wrong can be devastating. Noncompliance carries serious risks, including federal penalties of up to $2,236 per first violation and even potential criminal charges.
Key Compliance Requirements
To meet federal standards, your business must:
- Complete Form I-9 within three business days of the employee’s start date
- Accept only valid, unexpired documents from the approved list
- Retain I-9 records for three years after hire date or one year after termination, whichever is later
- Train HR staff and hiring managers on proper I-9 procedures, and conduct regular internal audits to ensure compliance
- Make I-9 forms available for inspection by authorized officials from the Department of Homeland Security (DHS), Department of Labor (DOL), or Department of Justice (DOJ) upon request
State and Local Requirements
Many states have enacted additional employment verification laws that complement federal requirements. Businesses must comply with both federal and state regulations:
- Some states mandate E-Verify use for all employers
- Certain states require additional documentation beyond Form I-9
- State penalties may apply in addition to federal sanctions
- Local jurisdiction requirements may also affect compliance obligations
E-Verify System Implementation
E-Verify is a web-based system that enables employers to electronically confirm a new hire’s employment eligibility. It compares information from Form I-9 with records maintained by the DHS and the Social Security Administration (SSA). While participation is voluntary for most employers, E-Verify is mandatory for certain federal contractors and in some states.
Benefits of Using E-Verify
- Offers real-time verification of employment eligibility
- Reduces the risk of hiring unauthorized workers
- Helps prevent document fraud
- Demonstrates good faith compliance efforts
- May offer safe harbor from certain enforcement actions when used correctly
E-Verify Requirements for Employers
- Enroll your company and sign the Memorandum of Understanding (MOU)
- Verify all new hires consistently. Never use E-Verify selectively or to pre-screen
- Collect and enter each employee’s Social Security number for the E-Verify case
- Complete verification within three business days of the employee’s start date
- Protect the confidentiality of employee information
- Post the required E-Verify and Right to Work notices in English and Spanish at your worksite (or online for remote workers)
Compliance Risk Management
Potential Penalties for Non-Compliance
Not only could your company suffer serious disruption, reputational damage, and possibly even debarment from government contracts, but you may also face financial and criminal penalties:
- First violation: $224-$2,236
- Repeat violations: Up to $22,363 per violation
- Knowingly hiring unauthorized workers: Criminal charges
Best Practices for Maintaining I-9 Compliance
- Establish standardized procedures for completing and storing Form I-9s
- Maintain a well-organized and accessible documentation system
- Conduct internal audits at least quarterly to catch and correct errors
- Provide ongoing compliance training for HR personnel and hiring managers
- Monitor updates from USCIS, DHS, and relevant state agencies
- Leverage electronic I-9 management systems to improve accuracy and streamline recordkeeping
Protecting Your Business
In today’s heightened enforcement environment, I-9 compliance is no longer optional—it’s essential to your company’s resilience and reputation. Regularly reviewing your I-9 practices and using E-Verify helps build a solid foundation for workforce compliance.
Small and mid-sized businesses are not immune to scrutiny. Prioritizing compliance minimizes the risk of costly penalties, reputational damage, and operational disruption.
Action Items for Business Leaders
- Review and update current I-9 procedures
- Assess and comply with any state-specific requirements
- Evaluate whether E-Verify enrollment is appropriate or required
- Schedule regular internal compliance audits
- Invest in ongoing training for HR and hiring teams
- Consult immigration compliance experts as needed
Maintaining robust I-9 and E-Verify compliance not only protects your business from penalties but also demonstrates a commitment to lawful employment practices and business integrity.
Take Action Now to Protect Your Business
Don't Let I-9 Compliance Put Your Business at Risk
With penalties reaching up to $2,236 per violation and the potential for criminal charges, can your business afford to gamble with I-9 compliance?
Your Next Steps:
With federal agencies ramping up I-9 audits and worksite inspections in 2025, small and mid-sized businesses are facing heightened scrutiny. At NorthstarPMO, our experienced fractional HR professionals help you not only stay ahead of enforcement risk, but also build durable, audit-ready compliance systems that support your broader business goals.
We’ll assess your current practices, identify vulnerabilities, and implement practical solutions that safeguard your organization from costly penalties. Whether you need help developing processes from the ground up or refining what you already have, we offer the tools, guidance, and strategic oversight to protect your business and keep your team focused where it matters most.
Our team will:
- Conduct an I-9 compliance assessment to identify gaps and hidden risks
- Develop a tailored compliance roadmap to bring your processes up to standard
- Recommend and implement digital I-9 and E-Verify systems to streamline compliance and recordkeeping
- Train your HR staff and hiring managers on proper I-9 procedures and audit readiness
- Monitor federal and state regulation changes to keep you consistently compliant
- Offer flexible fractional HR support so you gain senior-level expertise without the overhead of a full-time hire
When you work with NorthstarPMO, you gain a proactive partner in compliance—one who understands the operational realities of growing businesses and brings practical, results-oriented solutions to the table.
Limited Time Offer
Book your complimentary 30-minute consultation today and receive our exclusive "I-9 Compliance Checklist" ($297 value) at no cost.