I-9 employment eligibility verification

Editorial approval scope: The team checked current source fidelity, scope boundaries, dates, arithmetic, reader usefulness, practical workflow, and general-information limitations.

Form I-9 follows a federal hiring sequence

The USCIS Form I-9 hub provides the current form and employer resources. In general, an employee completes Section 1 no later than the first day of employment for pay. The employer completes Section 2 within three business days after that first day. A hire lasting fewer than three business days has a shorter Section 2 deadline under the current instructions.

Offer and acceptance come before Section 1. Keep an offer record, first day of work for pay, Section 1 completion, Section 2 completion, examiner, document route, correction history, reverification date when applicable, and retention date.

The employee chooses acceptable documents

The current Form I-9 instructions allow one acceptable List A document or one List B plus one List C document. The employee chooses which acceptable documents to present.

Managers should avoid requesting a particular immigration document, extra documents, or different documents because of citizenship, national origin, accent, name, or perceived status. The DOJ Immigrant and Employee Rights FAQs explain employment-verification discrimination and document-abuse boundaries.

Examination method needs its own gate

Standard Form I-9 completion uses physical document examination. A DHS-authorized alternative procedure can apply only when the employer and case meet its current conditions. Record which route was used and retain the evidence that the route allowed.

For any authorized representative, train the person, define secure transmission, inspect the completed form, and remember that the employer remains responsible for errors. A video call or uploaded image alone does not create an authorized remote route.

I-9 and E-Verify answer different questions

Form I-9 is the underlying employment-verification record. E-Verify is a separate electronic comparison that starts from a completed I-9. Enrollment in E-Verify does not remove the Form I-9 duties.

Prescreening an applicant through E-Verify is prohibited. A mismatch also starts a protected resolution process rather than proving that the person lacks work authorization.

Reverification and corrections preserve history

Reverification applies to defined expiring work-authorization situations. It is not triggered by every expiring identity document. Use the USCIS Handbook for Employers to distinguish reverification, rehire, receipts, extensions, name changes, and document rules.

Correct an error while preserving the original entry, the person making the correction, date, and explanation. Never backdate a late form or silently replace the historical record. A late form should show its actual completion date and a factual note.

Retention has a later-of calculation

Retain each Form I-9 for three years after the date of hire or one year after employment ends, whichever date is later. Calculate and record that destruction-eligibility date after termination.

Store I-9s and supporting copies, when retained, in a restricted system separate from broadly accessible personnel records. Define access, lawful inspection response, litigation hold, backup, and secure destruction.

A fictional hiring cohort

A fictional practice locks a cohort of 16 employees whose first day for pay occurred in July. Fifteen have Section 1 and Section 2 completed by their applicable deadlines: 15 of 16, or 93.8%. The late case stays in the denominator and records its actual completion date, reason, correction owner, and legal review.

Three employees also have a reverification decision due during the month. Two are completed by the valid deadline, while one remains held for current-document guidance: 2 of 3, or 66.7%. The practice reports completion and unresolved guidance separately.

Use a release checklist

Before closing a case, confirm:

• current form edition and correct employer entity
• accepted offer and first day for pay
• each applicable section completed by the responsible person
• employee-selected acceptable document combination
• authorized examination route and required annotation
• correction, receipt, extension, or reverification evidence
• restricted storage and calculated retention date
• E-Verify step when separately required

At this source check, USCIS says employers should use the 08/01/23 edition displaying the 05/31/2027 expiration date for completions beginning August 1, 2026. Store the edition and completion date in the case record, and recheck the USCIS form page rather than relying on a saved blank form.

Questions owners should ask

• Which legal entity hired the employee, and where will the person work?
• Which form edition and examination procedure apply on the completion date?
• Who checks timing, document choice, corrections, reverification, and retention?
• Can an employee report discrimination or an I-9 error through an accessible route?
• Does E-Verify, a federal contract, or a state rule add a separate step?

Answers should point to a current source, owner, due date, and retained record. Calendar reminders should never replace a case-level review of extensions or reverification.