What Changed on January 2, 2025

The Department of Homeland Security published updated civil monetary penalties for I-9 Employment Eligibility Verification violations, reflecting inflation adjustments required under federal law. These penalties apply to violations assessed on or after January 2, 2025, regardless of when the underlying violation occurred.

New 2025 I-9 Penalty Ranges:

• Paperwork Violations: $288–$2,861 per Form I-9 (increased from $281–$2,789)
• Knowingly Hiring Unauthorized Workers (First Offense): $716–$5,724 per worker
• Second Offense: $5,724–$14,308 per worker
• Third or Subsequent Offense: $8,586–$28,619 per worker

ICE determines base fine amounts using a violation percentage matrix that accounts for the number of substantive violations divided by total Forms I-9 presented during inspection. Five statutory factors—company size, good faith effort, seriousness of violations, unauthorized worker employment, and violation history—are then applied to adjust the final penalty amount upward or downward.

Who Is Affected in Nevada

All Nevada employers who hire employees after November 6, 1986, must complete Form I-9 for every new hire. Nevada places no additional I-9 requirements beyond federal compliance and does not mandate E-Verify usage except for public employers and contractors. However, Las Vegas, Henderson, and North Las Vegas employers in high-audit-risk industries face elevated enforcement pressure in 2025.

High-Risk Industries in Clark County:

• Hospitality & Casinos: High turnover, seasonal workers, multiple locations across Las Vegas Strip, downtown, and surrounding areas create unique compliance challenges
• Healthcare & Nursing: Rapid onboarding, conditional offers, travel nurses, and remote hires strain I-9 completion timelines at Valley Health, UMC, Dignity Health, and regional facilities
• Pharmaceutical & Biotech: Stringent credential verification requirements and regulatory compliance obligations increase exposure to paperwork violation penalties
• Staffing Agencies: Agencies must complete I-9 forms for payroll workers (not independent contractors), creating administrative burden and penalty risk at scale
• Remote & Distributed Workforces: Employers hiring remote workers relocating to Nevada face Section 2 authorized representative challenges and remote verification rule confusion

What Nevada Employers Should Do Now

1. Conduct Internal I-9 Audits
Review all current and terminated employee Forms I-9 (retention required for 3 years after hire or 1 year after termination, whichever is later). Identify and correct technical or procedural failures—missing signatures, incorrect dates, incomplete Section 2 entries—before ICE inspection. Document all corrections with dated explanations.

2. Train HR Personnel
Ensure HR staff, hiring managers, and authorized representatives understand proper I-9 completion timing (within 3 business days of hire), acceptable List A/B/C documents, remote verification procedures for E-Verify employers, and 2025 penalty structures. Training reduces error rates and demonstrates good faith compliance effort during audits.

3. Use Mobile I-9 Authorized Representatives
Lake Mead Mobile Notary provides on-site I-9 Section 2 verification services throughout Las Vegas, Henderson, and Clark County for remote employees, multi-location organizations, and employers without dedicated HR staff. Same-day mobile service ensures compliant document examination and Form I-9 completion within federal 3-day deadlines, reducing penalty exposure for paperwork violations.

4. Implement E-Verify (Optional but Strategic)
While Nevada does not mandate E-Verify for private employers, voluntary enrollment provides access to the Alternative Procedure for remote document verification via live video, reducing authorized representative costs and geographic barriers. E-Verify employers also demonstrate proactive compliance posture during ICE audits.

5. Monitor ICE Enforcement Trends
ICE projects over 12,000 I-9 audits in 2025, a significant increase from 6,450 in 2019. DHS reversed hospitality and restaurant enforcement shields in 2024, and worksite inspections targeting large Nevada employers are increasing. Subscribe to compliance alerts and track Notice of Inspection (NOI) timelines—employers receive only 3 business days to produce requested Forms I-9.

How Lake Mead Mobile Notary Helps Nevada Employers

Mobile I-9 Authorized Representative Services are available same-day throughout Downtown Las Vegas, Summerlin Centre, Green Valley, and all Clark County business districts. We serve pharmaceutical companies, healthcare systems, hospitality operators, staffing agencies, and remote-first employers requiring compliant Section 2 verification for new hires.

Book mobile I-9 verification: https://lakemeadmobilenotary.com/book or call/text (702) 748-7444.

This content is for informational purposes only and does not constitute legal advice. Employers should consult immigration counsel for compliance guidance specific to their circumstances.