• Gather I-9s from all former and current employees to ensure all forms are complete, updated, and not excessively retained.
• Section 1 of the Form I-9 should be reviewed for completion and updated by the employee if necessary.
• Section 2 and 3 of the Form I-9 should be reviewed by the employer for correctness and completion.

Internal audits must include a review of both current and former employees.

Step 1: Gather all I-9s for former employees and:

• Separate I-9s for former employees from I-9s for current employees. Ensure that former employees’ I-9s haven’t been kept past the required retention period. (I-9s must be kept for one year after termination or three years after the date of hire, whichever occurs later.)
• For I-9s of former employees that have not yet reached the retention threshold, review the forms as is done for current employees. Note that employers may not be able to correct certain Cross references.

Step 2: Gather all I-9s for current employees and ensure that:

• The company has a Form I-9 on file for all current employees hired after November 6, 1986;
• The company does not have a Form I-9 for nonemployees (such as volunteers and independent contractors); and
• All required fields are completed (in English), including signature fields for both the employee and the employer’s representative.

Reviewing Section 1

• Name, address, other last names used (if applicable), and date of birth should be completed. The address provided should be a physical address, not a P.O. Box.
• The Social Security number (SSN) is optional for employees in Section 1 unless the employer participates in E-Verify. E-Verify employers may require the employee to enter an SSN in Section 1 but need not examine the document for this section.
• The email address and phone number fields are optional in Section 1.
• The immigration status of the employee should be identified and the employee should have signed and dated Section 1.
• If a preparer or translator is used, Supplement A must be completed.

Reviewing Section 2

• Ensure that one document from List A (one document total) OR one document from each of Lists B and C (two documents total) have been recorded on the Form I-9.
• Ensure that the I-9 does not contain more documentation than is required.
• Check to verify that all required information has been recorded for each document (including document title, issuing authority, document number, and expiration date, if applicable).
• Ensure that documents recorded are:
  • Acceptable according to the form’s Lists of Acceptable Documents (note that this list has changed over time with different versions of the Form I-9, so employers must check to be sure the documents recorded were acceptable for the version of the Form I-9 that was completed); and
  • Recorded in the proper column (a List B document should not be recorded in the List A or List C column, for example).
• Verify that a representative of the company has signed and dated the form, attesting to having reviewed the documents.

Reviewing Supplement B (formerly Section 3)

Supplement B is required when an employee’s temporary work authorization expires (List B documents never need to be reverified) or when an employee is rehired. This section is optional when an employee (who is continuing employment) has a name change.

When Supplement B is used, be sure the proper sections are completed:

• For a name change, the top row is completed using information from Section 1 and the New Name sections are filled in as needed.
• For a rehire, the top row is completed with information from Section 1 and the date of rehire is inserted.
• For a reverification, the top row is completed using information from Section 1 and the reverification information is entered. The employer’s representative signs and dates this section to attest that the employee’s documentation has been reviewed.