ICE Expands I-9 Substantive Violations — $2,500 Per Error

In March 2026, the US Immigration and Customs Enforcement (ICE) overhauled its I-9 audit process, reclassifying routine paperwork errors as substantive violations carrying mandatory fines of roughly $2,500 per I-9.

These errors include dating errors, incomplete Section 2 entries, late document verification, missing Supplement B reverifications, and remote verification failures now trigger automatic liability. Each violation is a separate offense and the statute of limitations runs five years.

If there is concern that I-9 completion has not been fully compliant within your workplace, we recommend you audit I-9s to confirm accuracy.

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