One person should own policy, training, exception review, storage, retention, and agency-response readiness. Multi-location employers should also name site-level accountable users.

Write the exact steps for offer acceptance, Section 1, Section 2, document review, receipts, E-Verify if used, corrections, storage, and reverification.

Managers must not request more documents, different documents, specific documents, or reject valid-looking documents because of citizenship, immigration status, or national origin.

Do not rely on a saved local PDF as the permanent source of truth. Check the USCIS Form I-9 page before refreshing onboarding packets.

Using the form as a pre-screening tool creates discrimination risk. Build the workflow so I-9 opens after offer acceptance and before or at the start of paid work.

Make sure the attestation is signed, preparer/translator support is captured when used, and the employee does not leave required fields blank.

The employee may present one List A document or a List B plus List C combination. HR can explain the rule, but the employee chooses the documents.

For employment lasting less than three business days, complete Section 2 at hire and do not accept a receipt in place of the required document.

Missing document details are common technical failures. Build the form review so a second person catches missing expiration or document-number fields before filing.

I-9 review is a reasonable appearance standard, not a forensic exam. Rejecting valid-looking documents because they look unfamiliar can create document-abuse risk.

If someone else completes Section 2 for the employer, give written instructions, prohibit document steering, and review the completed form quickly. The employer remains accountable for the result.

The DHS alternative procedure is limited. A video call alone is not enough for employers that do not meet the E-Verify good-standing requirements.

The employee must transmit copies first. Review front and back when a document is two-sided, then compare the same documents during the live video interaction.

The current Form I-9 includes a corresponding box for alternative procedure use. Reverification handled through the procedure must be marked appropriately too.

The alternative procedure expands document-copy retention for those employees. Store copies with the I-9 or in a linked record that can be produced in an audit.

A qualified employer may limit the alternative procedure to remote hires while using physical review for onsite or hybrid hires, but the policy cannot be based on protected characteristics.

Once enrolled, employers must create cases for newly hired employees at enrolled hiring sites under the E-Verify rules. Do not create an E-Verify case for reverification alone.

Do not suspend, fire, delay training, reduce hours, or take adverse action because an employee is resolving a tentative nonconfirmation.

Receipts are allowed only in limited situations and are temporary. Give HR a due date, escalation path, and employee reminder process.

Schedule reminders far enough ahead to collect updated documentation, but do not reverify employees or documents that USCIS guidance says should not be reverified.

For renewal applications filed on or after October 30, 2025, do not assume an automatic EAD extension applies. Check current USCIS, eCFR, and any category-specific Federal Register notice.

If a former employee is rehired within three years and the existing I-9 can be used, inspect the prior form, confirm eligibility, and update correctly instead of duplicating records unnecessarily.

This is a best practice that makes audits cleaner and limits unnecessary access to identity and work authorization documents.

Build the retention date into the employee record so purge decisions are consistent and documented.

Document copies do not replace Section 2 completion. Inconsistent copying by citizenship status or national origin creates discrimination risk.

Electronic I-9 retention must do more than store a PDF. The system must support retrieval, readable reproduction, integrity controls, process documentation, and secure access history.

Audit by date range, location, acquisition group, or full population. Do not target employees because of citizenship, immigration status, accent, name, or national origin.

Use a dated correction trail. Preserve the original information where possible, initial/date corrections, and explain material fixes in a short audit note.

Know who receives a Notice of Inspection, who contacts counsel, where records live, how electronic audit trails are exported, and who communicates with agency officials.

Continuing-employment and prior-I-9 rules can reduce duplicate work, but they require deliberate review. Create an acquisition checklist before moving employees into payroll.