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How Long Do Employers Keep Form I-9? Understanding Retention Requirements

Learn the Legal Timeline for Form I-9 Retention and How It Ensures Compliance with Federal Regulations

Updated over 6 months ago

How Long Will My Employer Keep My Form I-9?

Under federal law, employers are required to retain the Form I-9 for a specific period to comply with employment eligibility verification regulations. This retention period helps ensure proper record-keeping and adherence to legal standards during audits or inspections.


What Are the Retention Requirements for Form I-9?

Employers must retain the Form I-9 for one of the following timeframes, whichever is later:

  1. Three Years After the Date of Hire:
    This applies if the employee remains actively employed with the company.

  2. One Year After Employment Ends:
    If the employee leaves the company, the employer must keep the Form I-9 for at least one year after their termination date.

For example:

  • If an employee works for two years and then leaves, the employer must retain the Form I-9 for three years from the date of hire.

  • If the employee works for five years and then leaves, the employer must retain the Form I-9 for six years (five years of employment plus one additional year after departure).


Why Do Employers Keep Form I-9?

Retaining the Form I-9 is crucial for the following reasons:

  1. Compliance with Federal Law:
    The Immigration Reform and Control Act (IRCA) requires employers to verify the identity and work authorization of all employees and maintain these records.

  2. Audits and Inspections:
    U.S. Immigration and Customs Enforcement (ICE) or other federal agencies may request Form I-9 records during an audit or inspection. Employers must produce these records promptly to demonstrate compliance.

  3. Legal Protection:
    Proper retention helps employers avoid penalties or fines associated with incomplete or missing records during regulatory reviews.


How Do Employers Store Form I-9?

Employers may store Form I-9 in either physical or electronic formats, as long as they ensure secure access and proper organization.

  • Physical Storage:
    Forms are typically kept in a secure, locked file cabinet, separate from other personnel files.

  • Electronic Storage:
    Digital records must be stored in a secure system with controlled access, ensuring data integrity and confidentiality.


What Happens After the Retention Period?

Once the retention period has passed, employers may safely dispose of Form I-9 records. It’s essential that any disposal method—such as shredding physical forms or securely deleting electronic records—prevents unauthorized access to sensitive employee information.


Key Points for Employees

  • Employers are legally obligated to retain Form I-9 for the specified period to meet compliance requirements.

  • Your Form I-9 contains sensitive information, so it’s stored securely by your employer.

  • If you have concerns about how your Form I-9 is handled, feel free to ask your employer about their storage and retention practices.


FAQs

1. Can I request a copy of my Form I-9 from my employer?
Yes, you can request a copy of your Form I-9 for your records, but the employer is not legally required to provide one unless requested as part of a legal or audit process.

2. What happens if my employer fails to retain my Form I-9?
Failure to retain Form I-9 can lead to fines, penalties, or other consequences during a federal audit or inspection.

3. Does the retention rule apply to remote employees?
Yes, the retention requirements apply to all employees, regardless of whether they work on-site or remotely.


Key Takeaways

  • Employers must retain Form I-9 for three years after hire or one year after termination, whichever is later.

  • Proper retention ensures compliance with federal regulations and protects employers during audits.

  • Employers are responsible for securely storing and disposing of Form I-9 records after the retention period ends.

By understanding Form I-9 retention rules, you can feel confident about how your employment records are managed in compliance with U.S. labor laws.

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