Form I‑9 compliance can’t wait: Why 2025 is the breaking point for manual processes

This July, an Ivy League university¹  received a clear directive from the Department of Homeland Security: provide all employee I-9 forms immediately.

That same week, a large regional retailer² had to suspend dozens of employees after documentation issues were identified during a review.

These recent enforcement actions highlight a critical reality for employers in 2025: compliance expectations have intensified.

These are not isolated events. They demonstrate that traditional processes, and even basic digital tools³, may no longer be enough. Increased scrutiny is already causing workforce disruption, onboarding delays, lost productivity during audits, and reputational damage. In more serious cases, compliance issues could escalate to legal exposure and executive-level attention.

Why this is happening now

There is a renewed focus on immigration worksite enforcement, signaling a shift in the priorities of the current administration. ICE⁴ has increased compliance inspections resulting in:

• More audits, across all industries
• Higher penalties, with fines of up to over $2,800 per I‑9 form
• Daily enforcement quotas for agents, often tied to employer violations

To some, 2025 marks a true tipping point in employment verification. The process has become seemingly more complex driven by evolving DHS regulations , remote verification, and heightened reverification requirements. Manual methods—or even outdated digital solutions—may no longer be sufficient. What was acceptable just a year or two ago might now expose employers to real compliance risk.

What should employers do now

Whether you’re using a manual process or relying on general onboarding software, it may be time to assess your I-9 compliance end-to-end.

Start with some best practices:

• Audit your existing I‑9 records for accuracy, completeness, version control, and missing fields
• Verify that your current solution aligns with I-9 documentation standards, including audit logs, time stamps, and reverification workflows
• Train your HR teams on remote verification, timing requirements, and document retention rules
• Implement audit readiness protocols, such as centralized record-keeping, access controls, and version tracking
• Modernize your process with technology that’s purpose-built for I-9 compliance—not just onboarding automation

Modern I-9 tools go beyond form collection. They can help employers manage reverifications, monitor policy changes, and maintain defensible records at scale.

The bottom line

The I-9 landscape is shifting fast. The window to get ahead of these changes is short. Organizations that act now will not only sidestep costly missteps but also gain an operational advantage—smoother onboarding, stronger client and employee trust, and less disruption when enforcement actions arise. Treating compliance as a strategic priority today will pay dividends in stability and readiness for years to come.

Contact us:

Derek Quashie – Partner, Immigration
Sherry Lin– Partner, Immigration
Raha Torabi – Director, Immigration

Sources

1. https://economictimes.indiatimes.com/nri/latest-updates/harvard-to-share-i-9-forms-of-university-employees-with-dhs/articleshow/123011159.cms
2. https://www.boston25news.com/news/local/market-basket-suspends-48-employees-massachusetts-store-after-dhs-audit/XPYMNZMT7RBSBOWOBTN2HEQXQI/
3. https://www.ft.com/content/40930c25-7b56-43d6-8898-30157ccd6d4a
4. https://www.washingtonpost.com/business/2025/06/11/trump-immigration-ice-crackdown-employers/