September HR Compliance: 3 Updates to Know
News September 11, 2026
In this September HR compliance roundup, Massachusetts employers should be aware of several important updates involving ICE response requirements, wage and hour enforcement, and employment eligibility. Here’s what HR teams need to know at a glance:
- New 48-Hour ICE Notice Requirement: Massachusetts employers that receive an ICE Notice of Inspection must now notify employees within 48 hours under the PROTECT Act. Employers should understand this new state deadline and how it fits into the federal I-9 audit process.
- Massachusetts AG Secures $1.46M in Wage and Labor Citations: The Massachusetts AG cited a Dunkin’ franchise operator and two staffing agencies for worker misclassification, late wages, unpaid travel time, and other labor violations affecting 100 employees.
- Temporary Protected Status (TPS): Several country-specific TPS designations and employment authorization periods have recently ended, changed, or remain affected by litigation. Employers should pay close attention to Form I-9 reverification requirements and current USCIS guidance.
Reminders:
- September: National Disability Employment Awareness Month
- September 30: Veterans form 4212 due to DOL, required of Federal contractors only
- October 12: Observance of Columbus Day
New 48-Hour ICE Notice Requirement for Massachusetts Employers:
On August 19, Governor Maura Healey signed the PROTECT Act, creating a new compliance requirement for Massachusetts employers. When an employer receives an ICE Notice of Inspection requesting Form I-9s or other employment records, employees in Massachusetts must be notified in writing within 48 hours.
This matters because employers may now be managing two timelines at once:
- Federal: Generally, three business days to produce requested I-9 records.
- Massachusetts: 48 hours to notify employees after receiving the Notice of Inspection.
Steps Massachusetts Employers Should Take Now
1. Update Your ICE Response Plan – Make sure that when you receive an ICE Notice of Inspection, your team immediately starts both the federal response process and the new Massachusetts employee notice process.
2. Prepare Employee Notice Templates in Advance – A sample template has been included on the mass.gov website I-9 template notice
3. Maintain Audit-Ready I-9 Records – Continue to conduct regular internal I-9 audits and make corrections according to the requirements on the USCIS site. If you need help with an internal I-9 Audit, AIM HR Solutions can help!
Additional Provisions of the PROTECT Act
While the new 48-hour employee notice requirement is the part of the law that most affects employers, the PROTECT Act also:
- Adds protections against certain immigration arrests at courthouses, public schools, childcare centers, and healthcare facilities.
- Limits when local police can ask about a person’s immigration status during routine interactions.
- Restricts how local agencies can work with federal immigration authorities on civil immigration matters.
- Prohibits new 287(g) agreements that allow local police to carry out certain federal immigration enforcement duties, except in limited situations.
- Creates new rules and procedures for immigration-related actions at courthouses beginning November 3, 2026.
Resources available:
Employers can access a sample I-9 inspection notice and USCIS guidance on correcting Form I-9 errors. AIM HR Solutions can also assist with I-9 audits and remediation.
AIM members can read the full HR Edge article here for additional guidance on the PROTECT Act and the new employer requirements.
Massachusetts AG Secures $1.46M in Wage and Labor Citations:
The Massachusetts Attorney General’s Office secured $1.46 million in citations against a Boston-area Dunkin’ franchise operator and two staffing agencies for wage and labor violations affecting 100 employees.
Key issues cited included:
- Worker misclassification
- Late wage payments
- Unpaid travel time
- Failure to provide required temporary worker notices
What employers should take away
The case is a reminder to review worker classification, wage payment practices, compensable travel time, and staffing agency compliance. Employers using third-party staffing firms should also understand where joint-employer responsibilities may apply.
Read the full announcement from the Massachusetts Attorney General’s Office.
Temporary Protected Status (TPS) Updates:
Updates for various countries are listed below. For detailed guidance, eligibility information, employment authorization updates, and the most current USCIS announcements, please refer to I-9 Central | USCIS.
|
Country |
TPS Update / Key Date |
|
Ukraine |
October 19, 2026 |
|
Sudan |
October 19, 2026 |
|
Lebanon |
November 27, 2026 |
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