ICE just made paperwork errors unfixable.
On March 16, 2026, ICE reclassified a wide set of Form I-9 errors as substantive violations. Many of them can no longer be cured after an inspection notice lands. What used to be a fixable typo is now a fineable finding.
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The good-faith defense is dead.
For years the Virtue Memorandum let employers lean on a good-faith posture. Minor I-9 errors were treated as correctable, not fineable. That protection no longer shields a defective form. Under the current penalty schedule, each paperwork violation carries a fine.
Per Form I-9 paperwork violation
$288 - $2,861
2025 federal penalty schedule
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"The era of treating I-9 mistakes as harmless paperwork is over. Inspectors are counting every blank field, and they are not handing out second chances."
Ruben Lugo
Former DoL investigator
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