When ICE shows up unannounced

By Justin Shirley, Roofing Contractors Association of Washington (RCAW).

Preparation means protection for your people and your business.

Disclaimer: Please note, this information is not legal advice and RCAW strongly encourages members to work with their local counsel to establish a compliance protocol that suits their unique needs.

They might arrive without notice — badges, clipboards, questions in hand. But with the right plan in place, that unexpected moment doesn’t have to spiral into chaos. For Roofing Contractors Association of Washington (RCAW) and beyond, being ready for a visit from U.S. Immigration and Customs Enforcement (ICE) isn’t just smart — it’s a sign of leadership. In a time when skilled labor is scarce and immigrant workers help keep jobsites moving, a proactive approach shows your team you’ve got their backs. Here's how contractors can stay compliant, calm and in control — no matter who comes calling.

The National Association of Home Builders (NAHB) has issued guidance to help businesses like ours stay informed, compliant and ready.

Here are a few key takeaways:

1 — Understand the law:

The Immigration Reform and Control Act (IRCA) requires all employers to verify identity and employment eligibility using
Form I-9. These forms must be kept on file for all active employees and be ready for inspection.

2 — Have a protocol:

Create a response plan. Designate a manager or leader on every site who knows how to handle an ICE visit. Ensure your team is trained in what to do and has access to legal counsel if needed.

3 — Know your rights:

If ICE arrives with a Notice of Inspection (NOI), you are legally entitled to at least three business days to respond. Use this time to review your records thoroughly with an immigration attorney. If a judicial search warrant is presented, it must clearly outline the scope of the search. Remember: employees are not required to speak to ICE or consent to a search.

4 — Debrief and reassure:

Once ICE leaves, take time to meet with your team and your counsel. Document what happened, review any materials taken and most importantly — reassure your employees. Let them know your business takes their safety, rights and dignity seriously.

Learn more about NAHB’s “When ICE Comes Calling. U.S. Immigration & Customs Enforcement on the Jobsite.”
We stand by the hardworking individuals who show up every day, climb ladders, brave the elements and build our communities.

By being proactive and informed, we protect not only our teams but the integrity and future of our industry. You can review the full guidance from NAHB here or reach out to RCAW if you’d like help putting together a site protocol. Let’s continue to support one another and stay strong as a community.

For more information about how to prepare for ICE on the jobsite, check out this Coffee Conversations with Trent Cotney of Adams and Reese.