What Oregon Employers Need to Know About I-9 Inspections and Employee Notifications

Federal immigration enforcement is ramping up—and Oregon employers are on the hook for more than just federal compliance. A little-known state law quietly passed in 2019 is now back in the spotlight, and failure to follow it could expose your organization to legal and reputational risk.  

If your business receives a federal request to inspect employment eligibility records, Oregon law requires you to notify your employees—and fast. Here's what organizations need to know to stay compliant. 

A Quick Refresher on Oregon’s Notification Law 

Oregon Revised Statute (ORS) 652.752, enacted in 2019, requires all Oregon employers to notify their employees within three business days of receiving a request from a federal agency—such as U.S. Immigration and Customs Enforcement (ICE)—to inspect records related to an employee’s identity or work eligibility. 

One of the most common scenarios that triggers this requirement is an I-9 audit, where ICE evaluates an employer’s I-9 forms to confirm that all employees are authorized to work in the U.S. 

What Employers Must Do 

If your organization receives a federal inspection notice, you are required to act swiftly and thoroughly. Here’s what compliance looks like under Oregon law: 

1. Post a Notice Promptly 

Within three business days, you must: 

• Post the federal inspection notice in a conspicuous and accessible location.
• Postings must be in English and the language you typically use to communicate with your employees. 

2. Notify Employees Individually 

You also need to make reasonable efforts to deliver individual notifications to employees in their preferred language, using your regular communication channels. These may include: 

• Email
• Pay stub messages
• Text messages (with photos of the documents)
• Office pickup notices 

3. Include Required Information 

The posted and individual notices must contain: 

• A copy of the federal agency’s inspection notice
• The date of the inspection
• The scope of the inspection, if known
• Your obligations as an employer in relation to the inspection
• A phone number for support provided by Oregon’s Bureau of Labor and Industries (BOLI), such as:
  • Equity Corps of Oregon: 1-888-274-7292
  • PCUN Service Center (Farmworkers): 503-902-0367

To support compliance, BOLI offers sample templates in six different languages that you can use when drafting your notices. 

Staying Ahead of the Curve 

Because federal agencies don’t always provide much lead time before an inspection, proactive preparation is key. Here’s how you can stay ready: 

✔️ Audit Your I-9 Records 

Conducting regular internal audits helps ensure your documentation is complete and accurate.

• If you're an Archbright member, explore the mozzo Resource Library for I-9 tools like our compliance keynote and audit spreadsheet.
• Members can also book an I-9 Records Review consulting service for expert assistance. 

✔️ Know When to Ask for Help 

If you receive an inspection notice or have questions about your legal obligations, we recommend seeking legal counsel. If you are an Archbright member, you may have access to Workplace Law Group as part of your member benefits. 

We’re Here to Help 

Understanding the intersection of federal enforcement and Oregon employment law can be challenging. If you are a member and have questions or need guidance: 

• Reach out via the HR Hotline
• Connect through mozzo Advisor Chat

At Archbright, we’re committed to helping you navigate evolving compliance landscapes with clarity and confidence so you can focus on what matters  
most—your people. 

Not a Member Yet? 

Archbright membership offers access to exclusive HR tools, legal resources, and expert support to help your organization navigate complex workplace challenges like I-9 compliance. If you're not yet a member, now is the perfect time to learn more about the benefits. 
 
👉 Visit archbright.com/why-join-membership to explore how we can support your HR and compliance needs