For the first time in more than 10 years, U.S. Immigration and Customs Enforcement (ICE) has updated its Form I‑9 inspection guidance on “technical” and “substantive” violations by publishing a Fact Sheet indicating that many errors that were previously treated as technical, i.e., curable within a 10-business‑day window in the event of an audit, will now be categorized as substantive violations subject to immediate penalty without the opportunity to correct them.