Arizona’s Employer Sanctions Law: How E-Verify Compliance Can Shield Businesses From Immigration Penalties
On Behalf of Coughlon Law Firm, PLLC. | Nov 21, 2025 | Immigration
Arizona takes hiring compliance seriously. Under the Legal Arizona Workers Act, often called the “employer sanctions law,” companies that hire or keep unauthorized workers risk business-license suspension or even a shutdown order for repeat violations.
At the center of the law is E-Verify. A.R.S. § 23-214 requires Arizona employers to run every new hire through the federal system and keep proof of that check for the longer of three years or the person’s employment. If your business wants state or local contracts or economic-development incentives, E-Verify is not optional.
Take the example of a small construction company that hires a crew member based on a photocopied ID and never runs E-Verify. Months later, a state investigation shows that the worker is unauthorized, and the employer can be ordered to terminate all unauthorized staff, submit quarterly reports, and operate under a three-year probation. A second violation at the same location can trigger permanent revocation of all licenses there.
Practical Compliance Steps
Train hiring staff on how to complete Form I-9 and use E-Verify. Put expectations in writing: a clear policy that you do not knowingly hire unauthorized workers and that every new hire goes through the same verification process. Keep I-9 and E-Verify records organized, and consider internal audits so small mistakes do not snowball.
In real cases, things do not unfold neatly. A notice might flag a Social Security mismatch, or you might hear conflicting information from an agency. If you brush it off, that can hurt. But if you ask questions, document what you find, and get legal guidance, it often helps show you meant well.
State and Federal Rules Working Together
Arizona’s law layers on top of federal immigration rules rather than replacing them. Employers still must complete federal I-9 forms while also using E-Verify for new hires. Good-faith use of E-Verify can create a rebuttable presumption that you did not knowingly employ an unauthorized worker, but it is not a shield if you overlook obvious signs of fraud.
Because immigration and employment laws differ by state and shift over time, Arizona employers often talk with counsel about these issues. At Coughlon Law Firm, we advise businesses on E-Verify, I-9 practices, and responses to audits. You can reach us at 602-636-0800 to discuss how these rules apply to your situation.
