A few days ago, two people in formal attire visited a business owned by someone I know and handed over a document. The title was Notice of Inspection, commonly referred to as an NOI, which is an I-9 inspection notice.

The owner's first question was, "Is this a raid?" To cut to the chase, it's not a surprise inspection. It marks the beginning of an administrative process requiring document submission.

However, it's not something to take lightly. How you handle the first three days can significantly affect the outcome later on. So, I've organized the confirmed information step by step.

The NOI is sent by HSI, which is under the federal Immigration and Customs Enforcement (ICE). It's an official request to submit employees' Form I-9 and related records.

According to ICE's official guidance, employers must submit the I-9 within at least three business days after receiving the notice. Exclude weekends and federal holidays, so be sure to check your calendar and mark the deadline accurately.

Agents are not allowed to demand documents on the spot. Don't panic and hand over any documents you can grab.

The first task is to read the notice carefully. It will specify which period's I-9s are required and whether other documents, like payroll records or quarterly tax reports, are also requested.

Next, contact an immigration attorney immediately. If it were me, I would make the call on the afternoon I received the notice.

Three days is shorter than you might think. Considering the time it takes for the attorney to review the documents, it's best to act as quickly as possible.

On the second day, gather all I-9s. This includes those of current employees as well as any former employees whose retention period has not yet expired.

The retention period is three years from the date of hire or one year from the date of termination, whichever is later. Check against your list to ensure no documents are missing.

There is one crucial caution here. After receiving the notice, you must not alter the I-9s.

In the past, there were instances where people filled in blanks secretly during the three days after receiving the notice. However, recent notices explicitly state not to change any documents after receipt.

Writing dates backward or obtaining new signatures will only escalate the issue. If you notice something missing, don't correct it; just make a note and discuss it with your attorney.

On the third day, organize the submissions. Decide whether to submit originals or copies, and follow the notice's instructions and your attorney's advice regarding the format.

Also, create a separate list of what you submitted. This single document can be very helpful later if there are disputes about what documents were exchanged.

Once the submission is complete, HSI will review the documents and notify you of the results. If there are no issues, you will receive a Notice of Inspection Results, commonly known as a compliance confirmation notice.

If a simple technical error is found, you will receive a notice granting at least 10 business days to correct it. If you fail to fix it within this period, the error will be considered a substantive violation.

If an employee's identification documents appear to be invalid or not theirs, you will receive a Notice of Suspect Documents. This involves employment issues with the employee, so you must respond with your attorney.

You also need to be aware of changes this year. ICE revised the I-9 inspection guidance on March 16, 2026, reclassifying several errors that were previously correctable as substantive violations.

For instance, if an employee's date of birth is missing in Section 1, or if dates are not filled in Section 1 or 2, these now fall under this category. Similarly, if the date of hire is missing in Section 2 or if the title of the employer's signer is not provided, it's the same.

In simple terms, blanks that used to allow for correction can now lead directly to fines. Honestly, I was a bit surprised by this point.

The fines can also be significant. Document violations can incur penalties ranging from $288 to $2,861 per I-9.

If you have ten employees, you'll need to multiply the amount by ten, which can be a heavy burden for small businesses. The actual amount is determined based on factors like company size, number of violations, and intent.

So, the real homework is to be done before receiving the notice. If you haven't received any notice yet, open your drawer today and check your I-9s.

The inspection process is simple. Check if the employee list matches the number of I-9s, and ensure that the date, signature, date of birth, and date of hire fields are not empty.

When making corrections, do not erase the original content; instead, strike through it and write the correct information, leaving the date and your initials. Corrections made before receiving the inspection notice are the only ones that matter.

Fixing things after leaks start in home repairs can cost several times more. I believe the same applies to I-9s.

If you have already received the notice, just remember to check the deadline, contact your attorney, gather documents, and refrain from making changes. Following these four steps will help you navigate the three days without panic.