The Trump administration continues to signal that worksite enforcement will become one of its highest immigration enforcement priorities. In a July 15, 2026 interview with the Center for Immigration Studies, Border Czar Tom Homan outlined plans for a dramatic expansion of I-9 audits, increased criminal investigations of employers, and closer coordination among ICE, the IRS, the Department of Labor (DOL), the Social Security Administration (SSA), and the Department of Justice (DOJ).
Although several of the proposals discussed have not yet been formally implemented, employers should view the interview as an important indicator of the administration’s enforcement priorities and begin preparing now.
Key Takeaways
- Massive expansion of I-9 audits anticipated. ICE is developing plans to dramatically increase employer audits through centralized review operations.
- Contractors may conduct initial I-9 inspections. Rather than relying solely on Homeland Security Investigations (HSI) agents, contractors could perform large-scale administrative reviews and refer suspicious cases to investigators.
- Employers—not just unauthorized workers—will be targeted. The administration emphasized pursuing criminal investigations against employers that knowingly violate immigration laws.
- Multi-agency enforcement is expanding. ICE expects greater coordination with IRS, DOL, SSA, DOJ and other agencies.
- Human trafficking and forced labor remain major priorities. Worksite enforcement is increasingly being linked to anti-trafficking investigations rather than simply immigration compliance.
- Companies should conduct proactive internal I-9 audits now.
A Closer Look
During the interview, Homan stated that worksite enforcement should become “a big part” of the administration’s overall immigration strategy.
Unlike previous enforcement efforts that often focused primarily on unauthorized workers, the administration appears increasingly interested in investigating employers that knowingly violate immigration laws, facilitate document fraud, engage in tax violations, or exploit unauthorized workers.
Perhaps the most significant announcement involved a proposal to create a centralized I-9 review operation.
Rather than assigning armed HSI special agents to review employment records, Homan proposed hiring contractors to perform large-scale I-9 audits.
Under the proposal:
- Contractors would review thousands of employer I-9 records.
- Administrative and criminal red flags would be identified.
- Suspected violations would then be referred to HSI investigators.
- HSI agents would focus on criminal investigations rather than routine paperwork reviews.
If implemented, this model could substantially increase the number of employers audited each year.
Ten Things Every Employer Needs to Know
1. Expect Significantly More I-9 Audits
The administration has clearly indicated that current audit levels are insufficient.
If contractor-supported reviews are implemented, ICE could conduct many more audits than has historically been possible.
Large employers should assume that the likelihood of receiving a Notice of Inspection will increase substantially.
2. Every Employer May Be at Risk
Historically, I-9 inspections have focused on industries with higher concentrations of unauthorized workers, including:
- Construction
- Hospitality
- Agriculture
- Food processing
- Manufacturing
- Landscaping
- Restaurants
- Staffing companies
However, nothing suggests future enforcement will be limited to those industries.
Any employer can be audited.
3. Criminal Investigations Will Receive Greater Attention
Homan repeatedly emphasized that ICE wants criminal prosecutions—not merely administrative fines.
Potential areas of investigation include:
- Knowingly hiring unauthorized workers
- False attestations
- Identity document fraud
- Harboring unauthorized workers
- Payroll fraud
- Tax fraud
- Human trafficking
- Forced labor
- Money laundering
- Conspiracy
For employers, this represents a significant escalation from traditional civil I-9 enforcement.
4. Multi-Agency Investigations Are Becoming the New Normal
According to Homan, future worksite investigations will increasingly involve multiple federal agencies.
Potential participants include:
- Homeland Security Investigations (HSI)
- Internal Revenue Service
- Department of Labor
- Department of Justice
- Social Security Administration
- Other federal investigative agencies
An I-9 audit may therefore expand into wage-and-hour investigations, tax audits, or criminal investigations.
5. Human Trafficking Remains a Major Enforcement Priority
The administration continues to link worksite enforcement with combating:
- Human trafficking
- Forced labor
- Labor exploitation
- Peonage
- Criminal labor schemes
Employers using labor contractors, subcontractors, staffing agencies, or temporary labor should ensure they maintain robust vendor due diligence programs.
6. I-9 Paperwork Errors Can Still Be Expensive
Even absent unauthorized workers, employers may face significant civil penalties for:
- Missing I-9 forms
- Late completion
- Improper reverification
- Missing signatures
- Incorrect document recording
- Failure to retain records
Simple administrative mistakes can quickly become costly when multiplied across hundreds or thousands of employees.
7. “No-Match” Issues Could Return
Although no formal policy has been announced, Homan discussed renewed coordination with the Social Security Administration.
Historically, SSA “no-match” letters have alerted employers that employee wage records do not match SSA databases.
Employers should monitor developments carefully should these notices again become part of federal enforcement strategy.
8. Internal Audits Are More Important Than Ever
Every employer should consider conducting privileged internal I-9 audits before ICE arrives.
A proactive audit allows employers to:
- Correct technical errors
- Identify missing documentation
- Improve onboarding procedures
- Train HR personnel
- Reduce potential penalties
Internal audits should generally be conducted under the direction of experienced immigration counsel to preserve applicable legal protections where available.
9. HR Training Is Essential
Many I-9 violations arise from inconsistent hiring practices.
Employers should ensure HR personnel understand:
- Acceptable documents
- Anti-discrimination rules
- Reverification requirements
- Remote verification procedures
- Retention requirements
- Electronic I-9 systems
- E-Verify obligations, where applicable
Training should occur regularly—not only after an audit notice arrives.
10. Worksite Enforcement Is Becoming a Business Risk
The administration views worksite enforcement as protecting U.S. workers, preventing labor exploitation, and combating criminal organizations.
For employers, I-9 compliance should now be viewed as an enterprise risk issue affecting:
- Legal compliance
- Corporate governance
- Reputational risk
- Business continuity
- Government contracting eligibility
- Mergers and acquisitions
- Workforce planning
Boards of directors and executive leadership should ensure immigration compliance receives appropriate attention alongside other regulatory compliance programs.
Practical Steps Employers Should Take Now
Employers should consider:
- Conducting attorney-directed internal I-9 audits.
- Reviewing hiring and onboarding procedures.
- Confirming proper document retention policies.
- Updating electronic I-9 systems.
- Reviewing E-Verify compliance where applicable.
- Auditing third-party staffing relationships.
- Reviewing subcontractor compliance obligations.
- Training HR personnel and hiring managers.
- Establishing protocols for responding to ICE Notices of Inspection.
- Developing crisis management plans for worksite inspections.
WR Immigration Perspective
The administration’s public statements indicate that worksite enforcement is entering a new phase. While some of the proposals discussed by Tom Homan—such as the use of contractors to conduct large-scale I-9 reviews—remain under development and have not yet been formally adopted, they reflect a clear enforcement direction. Employers should expect increased scrutiny of I-9 compliance, broader interagency cooperation, and a stronger focus on employer accountability where there is evidence of knowing violations or related criminal conduct.
Companies that proactively review and strengthen their I-9 compliance programs now will be better positioned to respond if enforcement activity accelerates in the months ahead.
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