ICE to Reinstate IMAGE Program Questionnaire to Reduce Undocumented Employment; 30-Day Comment Period Open
An ICE ERO officer monitors a detention facility in Buffalo, NY
U.S. Immigration and Customs Enforcement (ICE) has formally moved to reinstate, without changes, the information-collection requirements for its long-standing voluntary employer partnership known as IMAGE – the ICE Mutual Agreement Between Government and Employers.
Published today in the Federal Register (90 FR 52990), the 30-day notice marks the final step in renewing OMB Control Number 1653-0048, which covers Form 73-028, the IMAGE Self-Assessment Questionnaire. The form is the required first step for any company that wishes to apply for official IMAGE certification, and a final 30-day public comment period is now open through December 24, 2025.
The IMAGE program, launched in 2006 by ICE’s Homeland Security Investigations (HSI) division, is a fully voluntary partnership between the federal government and private-sector employers. Its primary goal is to strengthen hiring practices, reduce the employment of unauthorized workers, and promote a culture of immigration-law compliance.
While there is no legal requirement for any company to participate, employers that achieve IMAGE certification agree to adopt a series of “best practices” that go beyond basic Form I-9 obligations. Certified IMAGE members commit to enrolling in E-Verify, using the Social Security Number Verification Service (SSNVS), performing annual internal I-9 audits, submitting to an ICE audit of their I-9 records, and implementing robust protocols for handling no-match letters and potential document fraud.
In return, participants receive specialized training, direct access to ICE experts, and limited enforcement consideration—often described as “safe-harbor” benefits—so long as they maintain full compliance. To begin the certification process, interested employers must first complete Form 73-028, the Self-Assessment Questionnaire, which helps ICE evaluate a company’s size, industry, current compliance practices, and overall suitability for the program.
ICE estimates that roughly 66 companies will submit the questionnaire each year, with each response requiring approximately 90 minutes, resulting in a total annual public burden of 99 hours. The agency previously published a 60-day notice on August 18, 2025, and received no comments, making the current 30-day notice the final opportunity for public feedback before OMB renews approval of the collection.
No changes are being made to either the questionnaire or the underlying IMAGE program requirements. Although fewer than 500 employers have ever become IMAGE-certified, the program remains one of the few formal partnership options ICE offers to the private sector, and many federal contractors and companies in regulated or high-visibility industries continue to view IMAGE membership as valuable evidence of proactive compliance, especially during audits, due-diligence reviews, or supply-chain assessments.