ICE’s updated Form I‑9 inspection guidance significantly raises employer risk by reclassifying many previously “technical” errors — such as missing birth dates, incomplete Section 2 document details, or absent employer‑representative information — as substantive violations subject to immediate fines. Penalties now range from $288 to $2,861 per form, creating major exposure for large workforces. The guidance also tightens expectations for remote verification and electronic I‑9 systems, prompting employers to reassess onboarding, conduct internal audits, and retrain staff.

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