2026 US HR Audit Readiness: Preparing for the End of Good Faith Compliance

Federal immigration enforcement is shifting, and 2026 will bring a more structured, documentation-focused compliance environment for employers. 

For years, agencies often allowed employers a degree of “good faith” consideration in immigration related audits, meaning minor technical mistakes could be corrected without penalties if the HR teams could show the error was unintentional.

That flexibility is now narrowing. With increased enforcement budgets, stricter verification expectations, and renewed focus on employer accountability, US HR teams will need cleaner systems, stronger documentation, and consistent processes for audit readiness in 2026.

1. Why 2026 May Need a High Audit Readiness Year for US HR Teams

The increase in federal enforcement funding means more resources for worksite inspections, I-9 audits, and verification follow-ups. While this does not mean every employer will face an audit, it does mean:

• More routine checks across industries

• More requests for documentation

• More emphasis on whether HR teams are maintaining consistent, error-free processes

For HR teams, the takeaway is clear. Audits in 2026 may focus less on intent and more on accuracy and consistency. 

Processes that once passed under good faith consideration could now face higher scrutiny, making it essential for HR teams to standardize and document every step of their compliance workflow.

2. Strengthening I-9 Compliance: Priority Actions for US HR Teams in 2026

2026 will be the first full year when employers cannot rely on broad automatic extensions or informal leniency in I-9 reviews. With new verification rules and electronic payment mandates, expectations around accuracy and organization will rise.

HR teams should prioritize:

• Digital I-9 records that are easy to retrieve and audit

• Accurate documentation of every employment authorization update

• Consistent procedures for remote verification and re-verification

• Updated workflows that reflect new Department of Homeland Security requirements

A clean digital system means fewer delays, faster reviews, and lower risk during government inspections.

Visit the I-9 Audit Checklist here: https://www.waylit.com/post/the-i-9-audit-checklist-how-to-prepare-before-you-get-the-notice 

3. The Site Visit Reality: Preparing Your Front Desk and Managers

With expanded enforcement budgets, employers should expect an increase in site visits from the United States Citizenship and Immigration Services (USCIS) or Immigration and Customs Enforcement (ICE). These can occur at corporate offices, warehouses, job sites, retail locations, or any facility where employees work.

HR teams should ensure that:

• Reception staff know how to respond if an officer arrives

• Line managers understand what information can be shared

• Employees know who to contact internally

• Documentation is centralized and easily accessible

• I-9 files and supporting materials can be provided quickly if requested

Site visits do not need to be disruptive. Simple training, internal escalation paths, and organized records are enough to ensure a calm and professional response.

To access the HR guide for the immigration site visit: https://www.waylit.com/post/immigration-site-visit-hr-guide-the-essential-playbook-for-unannounced-visits

4. Actionable Steps for HR: Conduct a Mock Audit Before 2026

A  mock audit gives HR the opportunity to identify and correct issues before enforcement activity increases in 2026. It allows HR to:

• Identify missing or incomplete I-9 forms

• Update expiring work authorization documents

• Train managers on how to respond to compliance inquiries

• Set up a clean record structure for the new year

A proactive internal audit strengthens HR’s compliance foundation and reduces risk during formal reviews.

Way Ahead - How WayLit Helps HR Teams Stay Audit Ready

2026 will reward HR teams that implement organized, well-documented compliance workflows. Strong I-9 systems, trained staff, and proactive checks are the best way to stay ready as enforcement expectations rise.

Waylit supports HR teams with automated I-9 tracking, audit readiness tools, and compliance workflows that help organizations stay prepared throughout the year.