Compliance Stuff

Highlights U.S. Immigration and Customs Enforcement (ICE) issued updated guidance in March that materially changes how Form I-9 violations are classified. The long-standing Form I-9 fact sheet reclassifies numerous errors that had historically been treated as correctable technical violations as substantive violations subject to monetary penalties, a change that may significantly increase exposure to fines and enforcement risk for routine Form I-9 compliance errors. Employers should act promptly to review existing Forms I-9, address deficiencies and update internal compliance practices before ICE inspections potentially expose them to avoidable penalties. U.S. Immigration and Customs Enforcement (ICE) quietly issued updated guidance in March that materially changes how Form I‑9 violations are classified. ICE revised its long-standing Form I‑9  fact sheet  to reclassify numerous errors that had historically been treated as correctable technical violations as substantive violatio...

The U.S. Department of Homeland Security (DHS) has introduced a critical update to the E-Verify Status Change Report of which all employers using the system should be aware. As of July 15, 2025, the report now includes a “Revoked Document Number” field—an enhancement designed to help employers more accurately identify employees whose Employment Authorization Documents (EADs) have been revoked. Quick Hits DHS has updated the E-Verify Status Change Report to include a “Revoked Document Number” field, effective July 15, 2025, to help employers identify employees with revoked EADs. Employers must now compare the EAD number on an employee’s Form I-9 with the Revoked Document Number in the updated report to determine if reverification of work authorization is necessary. Background The Status Change Report was first launched on June 20, 2025 , as part of DHS’s efforts to improve transparency and compliance in the employment verification process. Its primary purpose is to alert employers if an...

As we have previously reported , the U.S. Department of Homeland Security is revoking employment authorization documents for certain individuals affected by the termination of humanitarian parole, including beneficiaries of the program for Cubans, Haitians, Nicaraguans, and Venezuelans (better known as “CHNV” ). On Friday, E-Verify sent an  email update  with guidance regarding steps that employers must take. Rather than wait for E-Verify to send a case alert, employers must do the following as soon as possible: Log in to E-Verify regularly to generate a Status Change Report . If the Status Change Report indicates that the EADs were revoked for current employees, immediately begin re-verifying each employee using Form I-9, Supplement B, and complete all re-verifications within “a reasonable amount of time.” Employers are directed  not  to create a new E-Verify case for any affected employee , but only to use Form I-9, Supplement B, for re-verification purposes. A “r...

  The Trump administration has already begun to   implement significant changes   in U.S. immigration policy and work authorization enforcement is expected to be a top priority. Employers should review their Form I-9 compliance now and prepare for potential I-9 audits and worksite visits, experts said. “Federal law requires employers to use Form I-9 to document employment eligibility,” said Sarah Hawk, a partner in the Atlanta office of Barnes and Thornburg. “ Although some employers use the paper version of Form I-9, others also participate in E-Verify, a voluntary web-based system that compares information from an existing Form I-9 to government records to confirm an employee’s authorization to work in the U.S.” A surge in I-9 audits is expected under the new administration. “We expect heightened scrutiny on I-9s as the Trump administration enters office,” Hawk said. “We’ve had increased interest from clients seeking legal help on I-9 compliance, and we are conducting s...