When you’re running infrastructure projects in Texas, there’s another challenge you can’t afford to ignore: the risk of an ICE audit.
In 2025, ICE (Immigration and Customs Enforcement) has stepped up worksite enforcement, and the construction industry remains one of its top targets. This makes audit readiness just as important as equipment readiness on your next job site.
Here’s what you need to know to protect your business, your projects, and your people.
What Is an ICE Audit and Why It Matters in Texas Construction
An ICE audit starts with a Notice of Inspection (NOI). Once you receive it, you have just three business days to produce your I-9 forms along with payroll records, onboarding policies, and E-Verify documents.
After reviewing your paperwork, ICE may issue:
- A Compliance Letter if everything checks out
- A Notice of Technical/Procedural Failures, which gives you 10 days to correct errors
- A Notice of Discrepancies or Suspect Documents, requiring employee responses
- A Warning Notice for issues that don’t yet merit fines
- Or a Notice of Intent to Fine (NIF), which can result in steep penalties
For Texas construction contractors, the stakes are high.
Imagine you’re a Fort Worth contractor and ICE suddenly requests 70 employee files across multiple job sites. Gathering that paperwork in just three days could throw your entire schedule into chaos.
That’s why audit readiness is part of protecting your bottom line.
Common ICE Audit Mistakes Contractors Should Avoid
Most ICE violations aren’t the result of fraud. They’re caused by small, common errors. Unfortunately, those “small” mistakes can cost you thousands of dollars per employee.
Some of the most frequent include:
- Missing signatures or dates on I-9 forms
- Accepting the wrong type of document, or one that’s expired
- Forgetting to re-verify temporary work authorizations
- Storing I-9s in personnel files, making them hard to retrieve quickly
Picture a Houston contractor who re-hires several workers but forgets to update their I-9 forms. In an ICE audit, that oversight could result in fines of more than $20,000 – even though the crew was authorized to work.
The lesson: In an ICE audit, documentation errors are just as damaging as genuine violations.
How to Prepare Your Business for an ICE Audit
The best way to protect your company is to take control of compliance before ICE arrives. Here are proven steps that make a difference.
Conduct Regular Internal Audits
Don’t wait until you get a Notice of Inspection. Review your I-9s at least once a year. Correct mistakes properly – initial and date changes, never back-date. Many Texas contractors bring in legal counsel for these reviews so that findings are covered under attorney-client privilege.
Standardize Your Process
Assign I-9 completion to one trained person or a small central team. This reduces the inconsistent practices that often happen when supervisors at different job sites handle the paperwork themselves.
Use Digital Tools
Paper forms get lost, and expiration dates are easy to overlook. Digital I-9 and E-Verify systems can centralize documents, flag deadlines, and make retrieval simple if ICE audits you.
Train Your Staff
From HR staff to project supervisors, everyone needs to understand the basics of I-9 compliance. Put written procedures in place for timelines, acceptable documents, retention rules, and how to respond to ICE.
Cowboy Trucking Supports ICE Audits with Compliant Drivers
ICE audits are becoming more frequent in 2025, and infrastructure contractors need to be ready.
At Cowboy Trucking, we understand that compliance (ours and yours) keeps your projects moving safely and on time. When crews and documents are in order, every load we haul supports a job that stays on track from start to finish.
Our promise: We will never allow our work to affect your own schedules. We get the job done. Always. Give us a call today.