Updated as of 3/5/2025
This EO focuses on immigration enforcement, with implications for employers through its impact on immigration programs. The U.S. Department of State and Homeland Security are tasked with thoroughly vetting individuals entering or residing in the U.S., especially those from high-security-risk regions.
I-9 Compliance & Audit Readiness: Checklist for Employers
HR Works has created a downloadable checklist covering key steps for Form I-9 and immigration audit readiness. This practical resource ensures your records are complete, accurate, and readily accessible in the event of an inspection. Download it today and take control of your compliance strategy.
Key items in this EO include:
- Increased Enforcement. The EO prioritizes strict enforcement of immigration laws, which may affect hiring practices and employment eligibility verification.
- Collaboration with Authorities. Federal, state, and local authorities are encouraged to share information, potentially increasing enforcement actions and audits.
Potential Implications/Considerations for Employers
- Strengthen Employment Eligibility Verification Practices
- Conduct periodic internal audits of I-9 forms to ensure that all active employees have a properly completed Form I-9.
- Train those responsible for the employer’s I-9 process on proper I-9 completion and recordkeeping procedures to ensure ongoing compliance.
- Consider enrolling in E-Verify to confirm employment eligibility. While voluntary for most employers, E-Verify may reduce the risk of compliance audits or penalties.
- Prepare for Increased Audits and Enforcement Actions
- Review policies and practices related to hiring, onboarding, and retaining foreign nationals to ensure compliance with federal and state immigration laws.
- Have a plan in place for responding to Immigration and Customs Enforcement (ICE) audits or investigations, including identifying legal counsel familiar with immigration compliance.
- Reevaluate Recruitment and Hiring Strategies
- Employers should consider recruitment strategies to attract U.S.-based talent, minimizing disruptions from stricter immigration enforcement.
- Review immigration sponsorship policies to determine the impact of potential delays or denials on workforce planning.
- Seek guidance from legal counsel to understand changes and ensure timely submissions of applications and renewals.
- Ensure that recruitment efforts are well-documented and compliant with Department of Labor requirements, such as proving the unavailability of qualified U.S. workers for the role.