Udder Pressure: I‑9 Compliance Crackdowns Hit Dairy Farms Hard

Dairy farms face rising I‑9 audits and mounting operational burdens in a broken labor system

I-9 Audit Surge: Dairies Caught in the Crossfire of Immigration Policy Fails

Dairy farms in Texas and South Dakota are facing an unexpected wave of I-9 audits, prompting renewed concern across the agricultural sector. Unlike ICE raids, these audits are quiet, sudden, and punitive—often resulting in mass terminations and unfillable labor gaps. Many in the dairy industry are sounding the alarm: the current immigration and compliance systems aren’t just outdated—they’re actively disrupting essential food supply chains.

Why Dairies Are Uniquely Exposed

Unlike seasonal agricultural operations that can participate in the H-2A guest worker program, dairy farms operate year-round. This disqualifies them from H-2A eligibility, despite their heavy reliance on immigrant labor to operate.

One dairy operation reportedly had to fire nearly 40 workers in a single week. Similar stories are unfolding across South Dakota, sparking fear of broader disruption.

Despite the mandatory use of E-Verify, audits are now revealing that some employees—who initially passed verification—were using falsified or mismatched documents. As a result, dairy employers are required to terminate workers within 10 days, creating operational strain and raising questions about the reliability of systems meant to ensure compliance in the first place.

Enforcement Without Clarity

While E-Verify has been promoted as a safeguard, it isn’t foolproof. The system doesn’t detect identity fraud or flag forged documents with perfect accuracy. This creates a legal gray zone where employers are penalized with fines of up to $28,619 for unknowingly hiring unauthorized workers who passed federal verification checks.

Worse yet, many audits appear to be triggered not by systemic failures, but by former employee complaints or conflicting political priorities.

“We also feel very strongly that it should not be on the employer to determine legal status of people in the country. That should be the job of the federal government,” says Rick Naerebout, CEO of the Idaho Dairymen’s Association.

Why This Matters Beyond Agriculture

The I-9 compliance issues facing dairy producers are a warning sign for all employers. Labor shortages are intensifying. Enforcement is ramping up. And immigration policy remains outdated and fragmented. The Wage and Hour Division of the U.S. Department of Labor recovered more than $6.8 million in back wages for agriculture workers in FY 2024.

If the E-Verify system can’t catch fraudulent documents, and H-2A can’t support year-round industries like dairy, businesses are stuck between compliance mandates and labor reality.

Clear I-9: Audit-Ready Compliance for High-Risk Industries

At HRlogics, we recognize that managing I-9 compliance in agriculture and other high-risk sectors isn’t just about checking boxes—it’s about protecting your workforce, operations, and reputation.

Clear I-9 by HRlogics offers multiple features that support dairy farms facing I-9 audits:

• Live I-9 Video Verifications to support distributed or on-farm teams
• Automated audit alerts for missing or inconsistent data
• Centralized dashboards to track compliance across states and sites
• Seamless E-Verify integration with clear issue tracking
• Tamper-proof digital storage and document trails for every employee

Stay Ahead of the Herd with Smart I‑9 Compliance

The surge in I‑9 audits across dairy farms highlights a growing enforcement trend and exposes the cracks in outdated labor systems. As farms struggle to balance compliance with constant labor demands, the risks of missteps are rising fast. From flawed E-Verify checks to the limitations of H-2A programs, the pressure is real—but preventable. Clear I‑9 gives agricultural employers the tools to stay compliant, avoid fines, and protect operations from disruption.

Let HRlogics handle your compliance so you can focus on farms, not forms. 

Schedule a Clear I‑9 demo today!