Hospitality / Restaurant| 5 min. read | 4/8/2026

How Hospitality Companies Can Avoid Costly I-9 Errors

Key Takeaways

  • Why should hospitality companies be concerned about I-9 compliance?
    I-9 and E-Verify compliance audits are expected to increase in 2026, with non-compliant employers exposing themselves to costly fines.
  • What are common pitfalls hospitality companies need to navigate when managing their I-9 compliance?
    Accidentally introducing bias into the process, using unacceptable documentation, missing deadlines, and misplacing forms are a few of the issues that can trip up employers.
  • What are the benefits of outsourcing I-9 management?
    Outsourcing I-9 management to a third-party provider can streamline the process, improve the candidate experience, reduce errors, and provide a secure centralized location for form storage.

In the rush to hire staff for seasonal peaks, train new recruits, and mitigate turnover, HR professionals can easily let administrative tasks fall by the wayside. However, this comes with considerable risks when it comes to I-9 and E-Verify compliance, where under the Trump administration. This growing focus on audits could expose companies to greater organizational challenges and increasing fines.

For some large companies, I-9 penalties can swiftly add up, as Asplundh Tree Experts, Co. learned in an historic, record-breaking lawsuit ending with the employer being forced to pay $95 million dollars in fines for hiring undocumented workers. Smaller businesses can find themselves forced to shut down, with first-time offense penalties ranging from $288 to $2,861 and scaling quickly with repeat violations.

The clock is ticking for hospitality providers, who need to ensure their hiring program is fully compliant with I-9 regulations before they are subjected to a random audit.

Challenges of I-9 Management in Hospitality

Since I-9 requirements are complex, mistakes are often easily overlooked, especially in the frantic world of hospitality hiring. When seasonal hiring is at its peak, HR managers may be inclined to rush through time-consuming administrative tasks, leading to potentially costly errors.

Common oversights include:

  • Accidental discrimination: USCIS requires employers not to discriminate based on national origin, citizenship, or immigration status. Practices that might seem innocuous, such as requiring a driver’s license as a proof of identity, could trigger an investigation or even a lawsuit.
  • Unacceptable documentation: At the other end of the spectrum, HR managers who are eager to see their new recruits start work as soon as possible can also be found liable for accepting inappropriate or expired documents as proof of identity.
  • Strict deadlines: HR managers are also on a tight timeline, with three business days to complete and sign Section 2 of Form I-9, starting from the applicant’s official hire date. Even minor delays can have costly consequences.
  • Lost or misplaced forms: Paper forms are a privacy risk, since they can easily be lost or misplaced, putting applicant data at risk.
  • Remote Hires: Properly inspecting original documents for remote employees can pose logistical difficulties, although virtual inspects may be authorized.
  • Retention and Storage: Improperly storing Form I-9s, such as keeping them in personnel files vs. separate, compliant files is a frequent compliance offense.

The chance of errors is increased if your company hires remote staff in customer service, management, and other positions, since it’s more difficult to remotely monitor compliance.

For more information about navigating I-9 challenges, read our new Form I-9 Hiring Survival Guide

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I-9 and E-Verify solutions help hospitality providers rise to the challenge

Overwhelmed by the challenges of managing I-9 requirements on a large scale? You’re not alone!

In recent years, background screening and HR services providers have developed new solutions to help hospitality companies deal with the administrative burden of I-9 compliance with convenience and efficiency.

That being said, not all providers are created equal. Finding the right partner can boost time and costs savings by minimizing errors and reducing your staff’s role in the I-9 compliance process.

Here are a few critical features you should look for in your I-9 management partner:

  • A single provider. To streamline the process, look for an I-9 and E-Verify solution that can be managed through the same company providing your background screening and onboarding services, since outsourcing to third parties can cause delays.
  • Applicant experience. Modern applicants are looking for a smart, user-friendly experience they can access from their mobile device. Promote a high compliance rate and make a great first impression by providing applicants with a smooth and hassle-free process.
  • ATS and HRIS integrations. Speed up your staff’s workflow by ensuring they can access I-9 forms and other HR administrative tasks within one centralized location. Look for a solution that can be integrated with your ATS or HRIS of choice for greater speed and convenience.
  • Demo. Before making a decision, request a product demo from your potential partner to confirm that the offered solution will meet your needs along with your staff’s and your applicants’ expectations.

First Advantage’s I-9 solution responds quickly, without relying on a third-party. Our auto-submission and integrated case management tools streamline the E-Verify process and include robust verifier options for Form I-9, including our proprietary Virtual I-9 Document Review to easily complete Section 2 and Supplement B.

Hospitality companies can also connect their I-9 program to their preferred ATS integration for greater convenience. Our applicant experience is modern, user-friendly, and compatible with mobile devices. Completed I-9 forms are retained along with all other I-9 documentation in our secure platform, making it easily accessible to employers for audit purposes.

Click here to learn more about our I-9 solutions.

Hospitality is a fast-moving industry, with sudden hiring peaks that create challenges when it comes to managing I-9 compliance. Avoid getting caught unprepared by a surprise audit with a fast and convenient I-9 and E-Verify management solution.

To set up I-9 for your hospitality screening and onboarding program, contact us.

Frequently Asked Questions

Employers must have their employees fill Section 1 no later than their first day of work. Section 2 must then be completed within three business days of their first paid workday. After having received acceptable documents, employers must examine them in order to confirm their employees’ identity and work authorization.

Requirements are listed on the USCIS website. Employers must review either one item from List A to establish both identity and employment authorization; or one item from List B to establish identity and one item from List B to establish employment authorization.

Employees are provided with clear guidance and step-by-step validation as they fill out Form I-9. Task notifications and reminders are sent for timely completion, while cases are automatically integrated with E-Verify. Employers have access to a large suite of in-person, remote in-person, and virtual verifier options to fill out Section 2. Reporting insights allow for simplified management of the entire process.


This content is offered for informational purposes only. First Advantage is not a law firm, and this content does not, and is not intended to, constitute legal advice. Information in this may not constitute the most up-to-date legal or other information.

Readers of this content should contact their own legal advisors concerning for their particular circumstance. No reader, or user of this content, should act or refrain from acting on the basis of information in this content. Only your individual attorney or legal advisor can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation. Use of, and access to, this content does not create an attorney-client relationship between the reader, or user of this presentation and First Advantage.

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