The Hiring File Got Hotter
I-9 Compliance for Florida Restaurants: 3 Days, $2,861 per Form
ICE initiated just over 264 Form I-9 inspections in all of FY 2024. At the last worksite-enforcement peak, in FY 2019, it ran 6,456. The audit program spent four years at a few hundred a year, and that collapsed baseline is what the current administration began rebuilding in 2025.
| Fiscal year | Inspections initiated |
|---|---|
| FY2019 | 6,456 |
| FY2021 | 203 |
| FY2022 | 624 |
| FY2023 | 301 |
| FY2024 | over 264 |
There is no official 2025 audit count yet, so treat the big numbers in circulation with care. The most-quoted figures (2,540 in a quarter, more than 5,200 in a year) come from ICE's 2018 two-phase operation, and the "ten times the old pace" claims appear in vendor and law-firm commentary, not in any published series.
What the record does show is everything around the audit being rebuilt: raids on restaurants and hotels through 2025, $8 billion for ICE hiring, a workforce the agency says doubled in a year, and a March 2026 rewrite of the I-9 penalty rules that removed the correction window for the most common paperwork errors. The audit count follows the apparatus. The file you keep today is the one that gets inspected.
An audit notice starts a three-day clock
An I-9 audit begins when ICE serves a Notice of Inspection. From that moment you have at least three business days to produce your original I-9s, and agents usually request payroll records, a list of current and former employees, articles of incorporation, and business licenses alongside them. The review that follows can take months.
The error rules changed on March 16, 2026. Technical failures still get a correction window of at least ten business days. But ICE's updated inspection fact sheet now lists a long set of common mistakes as substantive violations, which get no correction window at all: a missing date of birth or attestation checkbox in Section 1, missing document details in Section 2, an electronic I-9 system that can't produce compliant audit trails. Each substantive violation or uncorrected failure draws a fine of $288 to $2,861 per form.
Two more clocks sit inside the process. If a new hire presented a receipt for a lost, stolen, or damaged document, you have 90 days to verify the replacement, and missing that window is itself a substantive violation. If the audit ends in a Notice of Intent to Fine, you have 30 days to request a hearing. After that the fine becomes a final order, with no appeal.
Florida's alcohol regulator is now an immigration partner
In April 2025, the Division of Alcoholic Beverages and Tobacco (ABT) signed a 287(g) Task Force Model agreement with ICE. Under the agreement, ABT's 106 sworn officers (not its civilian inspectors) gained federal authority to perform immigration enforcement functions. By January 2026, ABT had logged 375 shifts and 2,894 hours under the agreement [source: DBPR press release, Jan 7, 2026]. The agency split is covered in our Florida regulator briefing.
In a May 1, 2025 Operation Tidal Wave briefing, Governor DeSantis said ABT and other Florida regulatory agencies operate in "target-rich environments," and that their routine inspection and investigative duties put special agents in contact with people who may be in the country illegally.
No one has publicly documented a case where a routine alcohol compliance visit triggered an immigration check. The legal authority for sworn ABT officers exists under the agreement, but how and whether it gets used during routine visits remains an open question.
The federal money behind this
The One Big Beautiful Bill Act, enacted July 4, 2025, allocated $8 billion for ICE personnel. The hiring plan: 2,500 new positions in FY 2025, then 1,875 per year through FY 2029, for a total of 10,000. ICE reported doubling its workforce from 10,000 to 22,000 officers and agents during 2025.
Separately, ICE asked the IRS for taxpayer records covering about 1.28 million people under a data-sharing memorandum. The IRS matched and shared data for roughly 47,000 of them.
Hospitality is a named target
On June 17, 2025, Reuters reported that DHS told staff raids on hotels and restaurants should continue. A brief internal pause (a June 12 email) was reversed within days. A DHS spokesperson said: "There is no safe harbor, whether it be a church or a courthouse or a worksite."
An analysis of Census Bureau survey data puts the foreign-born share of Miami's hotel workforce at 65%. The sector's workforce profile makes it a focus for enforcement, and federal officials have said so openly.
Florida has already seen large-scale actions. In May 2025, a Tampa worksite operation led to 33 arrests, and a Tallahassee raid the same month brought more than 100. Both were construction-site operations, but restaurants are in the record too: in February 2025, the owner of a Jacksonville Beach sushi restaurant pleaded guilty to harboring undocumented workers, forfeiting a house and a transit van as part of the plea.
| Date | What changed |
|---|---|
| Apr 2025 | ABT signs a 287(g) Task Force Model agreement with ICE |
| May 2025 | Tampa worksite operation (33 arrests) and Tallahassee raid (100+ arrests) |
| Jun 17 2025 | DHS tells staff raids on hotels and restaurants should continue (Reuters) |
| Jul 4 2025 | OBBBA enacted, allocating $8 billion for ICE hiring |
| Jan 2026 | ABT logs 375 shifts and 2,894 hours under the 287(g) agreement |
| Mar 16 2026 | I-9 penalty rules rewritten; correction window removed for substantive errors |
E-Verify and the I-9 form deadline
SB 1718 (codified at F.S. 448.095) makes E-Verify mandatory for private employers with 25 or more employees. You have three business days after a new hire's first day of paid work to run the verification, and you keep the records for at least three years.
State enforcement is graduated. If the Department of Commerce finds you didn't use E-Verify, it notifies you and gives you 30 days to cure it. A third violation inside 24 months brings a $1,000-a-day fine until you prove compliance, and at that point noncompliance is grounds for suspending your licenses until it's cured.
There's also a form transition. USCIS issued a new I-9 edition in January 2025. Older forms dated 08/01/23 stay valid until the expiration date printed on the form: some expire on July 31, 2026, others on May 31, 2027. Check the edition and expiration date on the forms you use, and update any electronic I-9 system that carries the July 31, 2026 expiration by that date. Existing I-9s completed on the old form for current employees can stay on file.
The money is appropriated, the officers are hired, and the penalty rules are rewritten. Whatever the official 2025 audit count turns out to be, the records ICE will ask for are the ones you keep now. Our Florida employment compliance resources cover the I-9 and E-Verify files that sit behind the audit.
This briefing is based on sources available at publication and is for general information only. It doesn't constitute legal advice. For advice on your specific situation, consult a qualified professional.
Produce the record when you're asked, not a week later.
Florida operators keep I-9 and E-Verify checks, SB 606 disclosures, and $15 minimum wage records current. Duty Room keeps the evidence and deadlines aligned with your HR adviser.