Every HR department knows the Form I-9 is required—but few realize how easy it is to make small, costly mistakes.
In 2025, increased enforcement from USCIS and ICE means those “small mistakes” can quickly become six-figure audit risks. To find out how HR professionals are navigating today’s compliance landscape, we spoke with eight leaders across industries including healthcare, construction, retail, and higher education.
Here’s what they told us about the most common I-9 mistakes—and how they’re fixing them.
Several HR leaders admitted confusion around employment authorization document (EAD) auto-extensions. Many didn’t realize that some categories automatically extend work authorization while others do not.
The risk: Employers who reverify too soon—or fail to reverify on time—can face penalties for document abuse or unauthorized employment.
The fix: Keep an updated list of EAD categories eligible for automatic extensions and use digital I-9 systems that alert teams when reverification dates actually apply.
Multiple leaders cited the three-business-day deadline for Section 2 as one of their top pain points. Delays often occur when remote hires or decentralized teams are involved.
The fix: Use remote I-9 verification tools that maintain compliant audit trails, and train local managers to collect and review documentation promptly.
Related: How to Handle an ICE Audit
Many HR managers believe requesting multiple documents “for accuracy” protects them. It doesn’t—it can actually lead to discrimination violations under IRCA.
The fix: Follow the rule: one List A document OR one List B plus one List C. Train hiring managers to never specify which documents employees should provide.
Related: Acceptable Documents for I-9 Compliance
For large employers, especially multi-state operations, record inconsistency was the biggest compliance challenge. Some stored I-9s on paper, others in HRIS systems without audit logs.
The fix: Standardize your process company-wide. If you use paper I-9s, digitize and centralize them. If using software, confirm it generates audit trails and reverification alerts.
Related: I-9 Compliance for Multi-Location Employers
Several HR leaders confessed that reverification timelines—and which documents actually require it—are often unclear.
The fix: Review USCIS guidance regularly and ensure your system flags only those documents that expire. U.S. passports and green cards, for example, never require reverification.
Even with digital onboarding tools, missing employee signatures or unchecked attestation boxes remain common I-9 mistakes.
The fix: Automate validation so incomplete forms can’t be submitted. Conduct quarterly self-audits to catch old errors before an ICE inspection does.
A surprising number of HR teams said they didn’t know who would respond if an ICE audit notice arrived.
The fix: Create an audit response plan outlining who collects documents, where records are stored, and how the team will communicate with government investigators.
Try our I-9 Risk Calculator to estimate your potential exposure before an audit.
Across the board, HR leaders agreed: most I-9 issues aren’t caused by fraud—they stem from misunderstanding and inconsistency.
With civil fines ranging from $288 to $2,861 per paperwork error in 2025, even unintentional mistakes can create real financial exposure.
That’s why leading employers are investing in:
At i9 Intelligence, we help HR teams turn compliance risk into confidence. Our digital platform automates I-9 verification, E-Verify integration, and reverification alerts—all with a complete audit trail.
Next steps for HR leaders: Run your organization through our free I-9 Risk Calculator or book a 15-minute compliance review with an i9 Intelligence expert.
