Frame 64

I-9 Compliance Risk Diagnostic

10 questions · 5 minutes · defensibility score

This diagnostic does not require an ICE notice, audit trigger, or document upload.

Why Companies Take This Diagnostic

Most organizations don’t realize I-9 risk exists until

By then, remediation becomes reactive and expensive.

This diagnostic gives you a baseline defensibility score early, privately, and without disruption.

What This Diagnostic Reveals

In under 5 minutes, you’ll uncover

How This Works

Select the best answer for each question.

Add the points at the end.

Higher score = Higher compliance risk

Score

Risk Level

Suggested Action

0–10

Low Risk

Monitor annually

11–20

Moderate Risk

Corrective action recommended

21–30

High Risk

Formal remediation advised

31-40+

Critical Risk

Urgent remediation + legal counsel

I-9 Compliance Risk Diagnostic Questionnaire

Section A: I-9 Form Integrity

1. What percentage of your active employees have a completed I-9 on file?

2. Were Section 1 and Section 2 completed within required timelines?

3. Are corrections made using compliant annotation practices?

Section B: Workforce Risk Profile

4. Portion of workforce requiring work authorization tracking?

5. Do you actively track reverification dates?

6. Employees continued working past authorization expiration?

Section C: Systems & Process Control

7. Where are I-9s stored today?

8. Do you conduct internal I-9 audits?

9. Is E-Verify used correctly?

Section D: Event-Driven Risk

10. Events in last 3 years?

Section E: Document Verification & Acceptance

11. Section 1 completion accuracy?

12. Section 2 document verification?

Section F: Retention, Purging & Form Version Control

13. Correct/current Form I-9 version?

14. Retention rules followed?

Your I-9 Risk Score: 0 / 60

What your score means

🟢 Low Risk (0–15)

You appear structurally compliant.

Recommendation

Annual audit +
monitoring.

🟡 Moderate Risk (16–30)

Correctable gaps likely exist.

Recommendation

Targeted remediation
before audit.

🔴 High Risk (31–45)

Material exposure with fine risk.

Recommendation

Formal remediation with legal oversight.

🚨 Critical Risk (46-60)

Audit or enforcement exposure likely.

Recommendation

Immediate remediation + counsel-led strategy.

A Quick Reality Check

ICE penalties are rarely about intent.
They are about paperwork defensibility.
 
Two companies can have identical hiring practices — the one with structured documentation pays dramatically less.

Estimated Fine Exposure Ranges (Illustrative – Not Legal Advice)

Based on publicly available ICE/DHS civil penalty adjustment ranges:

Paperwork / Technical Violations

Examples: missing dates, incomplete sections, improper corrections, late completion

Approximate Range: $300 – $3,000 per form

Substantive Violations

Examples: failure to properly verify identity or work authorization

Approximate Range: Higher within the same per-form range depending on severity

Knowingly Hiring or Continuing to Employ Unauthorized Workers

Approximate Range: $700 – $30,000+ per violation

(Amounts escalate significantly for repeat findings)

How Your Score Relates to Exposure

Low Risk (0–15)

Minimal per-form exposure if audited; typically correctable documentation gaps.

Moderate Risk (16–30)

Potential $10K – $100K+ cumulative exposure depending on employee count and error frequency.

High Risk (31–45)

Potential six-figure exposure if systemic documentation or verification issues are identified.

Critical Risk (46–60)

Potential significant financial and operational exposure, particularly if unauthorized employment or repeated violations are found.

Disclaimer: These figures are general public reference ranges intended for planning awareness only. Actual penalties vary based on audit findings, company size, good-faith efforts, prior history, and regulatory discretion. This diagnostic does not constitute legal advice.

Who This Is For

What This Is Not

It is simply a risk visibility tool.

Why This Matters

The goal of I-9 remediation is not perfection; it is defensibility.
Structured corrective action can significantly reduce fines, disruption, and reputational risk before regulators ask questions.

Next Step

Schedule a Confidential I-9 Risk Review

No obligation. No document upload required.

Just clarity on where you stand.