Worksite enforcement is ramping up fast. In 2025, Immigration and Customs Enforcement (ICE) has significantly increased the number of Notices of Inspection (NOIs), onsite raids, and employer investigations—especially in industries like construction, agriculture, food service, and hospitality.
Many businesses assume that ICE won’t target them or that basic onboarding practices will protect them. That’s a costly mistake.
The 2025 worksite enforcement surge is part of a broader policy shift. Key drivers include:
— Political pressure to crack down on undocumented employment
— Audit quotas set by DHS for field offices
— Increased collaboration between ICE, the IRS, and local law enforcement
— Targeting of “sanctuary cities” and high-risk sectors
Even technical errors—like missing I-9 signatures or outdated forms—can lead to five-figurepenalties per employee.
If your business is selected, here's how the ICE process typically unfolds:
1. You receive a Notice of Inspection (NOI)
You have 3 business days to submit I-9s, payroll records, and employee lists.
2. ICE reviews your documents
Agents look for both paperwork violations and “knowingly hiring” infractions.
3. You may receive:
— Notices of Suspect Documents
— Notices of Intent to Fine
— Civil or even criminal penalties depending on severity
Even a well-intentioned employer can face thousands in fines if their I-9s aren’t complete, consistent, and compliant.
1. Conduct an internal I-9 audit today
Start by reviewing active and terminated employee forms. Log any errors or missing documents, and correct them following USCIS guidelines. For more information on conducting an internal I-9 audit checkout our guide: How to Self-Audit Your I-9s.
2. Centralize your I-9 records
Scattered paper forms across departments or locations = major risk. Use digital I-9 software with secure document storage and audit logs.
3. Use the latest version of the I-9 form
Ensure you're using the DHS-approved version, updated in August 2023.
4. Reverify work authorizations on time
Set automated reminders for expiring work authorization documents. Missing a re-verification deadline can trigger penalties.
5. Train managers on proper I-9 completion
Inconsistent processes across hiring locations cause most compliance issues. Use a tool like i9 Intelligence’s remote verification and standardized workflows to reduce error rates.
6. Have a response plan in place
Know how you'll respond to a Notice of Inspection. Assign a point person and maintain a pre-audit file of updated I-9s and supporting documents.
ICE has increased enforcement in these sectors:
— Construction: Targeted because of its high turnover, jobsite hiring, and remote onboarding.
— Hospitality: Increasing enforcement due to the large immigrant workforce and seasonal employment.
— Restaurants: Enforcement is rising because of decentralized operations, migrant workers, and franchise hiring practices.
— Agriculture: Targeted due to its migrant labor, seasonal hiring, and E-Verify inconsistencies.
— Staffing: Increasing scrutiny thanks to fast-paced placements, rehires, and inconsistent records.
“Too often, HR teams wait until they receive a Notice of Inspection before addressing I-9 risk. By then, it’s too late to correct past errors.” — Jed Butler, CEO i9 Intelligence
ICE does not offer a grace period once a Notice of Inspection is issued. For multi-location businesses, staffing agencies, and seasonal employers, this means even minor errors can be multiplied across hundreds of records. Failing to act proactively doesn’t just result in fines. It can lead to business disruption, brand damage, and—for some industries—license suspensions or contract losses. Preparation is the only protection.
Book a free compliance call with our team or use our I-9 Risk Calculator to understand your current risk, from there we’ll build a strategy together to get your business compliant.
— Trusted by businesses across hospitality, construction, agriculture, staffing, and more
— Over 2 million I-9s processed compliantly
— 100% expert U.S.-based support
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