ICE's March 2026 guidance reclassifies a broad range of previously "technical" Form I-9 errors, such as missing dates, incomplete document fields, improper corrections, as "substantive" violations now subject to financial penalties, eliminating much of the remediation flexibility employers previously had during inspections. ICE is simultaneously increasing worksite inspection frequency and scrutinizing remote document verification procedures.

Checkr Takeaway: Employers using Checkr's onboarding and identity verification products should audit I-9 records for errors now classified as substantive violations and confirm that remote verification workflows meet ICE's updated standards ahead of any inspection.