I-9 Reverification: When It’s Required and What to Do

An employee’s driver’s license expires next month. Another employee’s Permanent Resident Card expires this summer. A third employee has an Employment Authorization Document approaching its expiration date.

Do all three need I-9 reverification? No. Treating every document expiration as a reverification event creates unnecessary work and can lead to improper document requests.

For employers hiring at volume, the challenge is separating document expiration from expiration of employment authorization—and giving HR a consistent process for acting on the difference.

What is I-9 reverification?

I-9 reverification is the process employers use to confirm that an employee remains authorized to work when previously documented, temporary employment authorization expires. Employers record reverification in Supplement B, Reverification and Rehire, of Form I-9.

It is not a routine requirement to complete an entirely new Form I-9. It also is not an opportunity to repeat identity verification or request updated copies of every document in an employee’s file.

The starting question is: Does this employee’s employment authorization require reverification? An expiration date alone does not answer that question.

For the broader onboarding process, see our Form I-9 compliance checklist. Reverification needs its own controls after onboarding is complete.

When is I-9 reverification required?

Employers generally must reverify employees whose temporary employment authorization expires. The review should account for the employment authorization information recorded in Section 1 and the documents recorded in Section 2 or a previous Supplement B entry.

Common situations include employees who presented:

• An Employment Authorization Document, generally Form I-766, showing time-limited work authorization.
• Documentation supporting employment in a temporary immigration classification, where continued work authorization depends on applicable status and employment conditions.
• Temporary evidence of permanent resident status, such as a temporary Form I-551 stamp, which can require reverification even though an ordinary Permanent Resident Card does not.

Generally, reverification must occur no later than the applicable employment authorization expiration date. However, an automatic extension or another applicable rule may permit continued employment beyond a date printed on a document.

That makes classification important: a calendar reminder should trigger a review, not an automatic conclusion that work authorization has ended.

Which documents should not trigger reverification?

Several common document expirations do not require employers to reverify an employee.

U.S. passports and citizenship documentation

Do not reverify U.S. citizens or noncitizen nationals. If a U.S. passport used for the original I-9 later expires, that expiration does not create a reverification requirement.

Permanent Resident Cards

Do not reverify lawful permanent residents merely because their Permanent Resident Card, Form I-551, expires. This includes conditional permanent residents who presented a Permanent Resident Card.

Distinguish the card itself from temporary evidence of permanent resident status. Temporary evidence can carry different reverification requirements, so HR should not apply a blanket rule to everything labeled “I-551.”

List B identity documents

Do not reverify a List B identity document, such as a driver’s license or state identification card, simply because it expires.

List B documents establish identity, not employment authorization. Renewing an identity document for another legitimate business purpose is separate from Form I-9 reverification.

How to complete I-9 reverification

Use the current Form I-9 instructions and the USCIS Handbook for Employers, M-274 to confirm the requirements for the employee’s situation.

1. Confirm the actual deadline

Review the original I-9, any previous reverification entries, and relevant supporting records. Determine whether the recorded expiration date remains the correct deadline.

If the employee may qualify for an automatic extension, evaluate that before requesting a replacement document or deciding the employee cannot continue working. Do not assume that a pending application, by itself, extends employment authorization.

2. Explain the employee’s document choices

For reverification, employees may present an acceptable List A or List C document establishing continued employment authorization. They do not have to present the same document used at hire.

Do not insist on a new Employment Authorization Document, green card, or other specific document when another acceptable document satisfies the requirement. Do not request a List B document for reverification.

Where a receipt or document combination is offered, check the applicable USCIS rules rather than assuming every receipt is acceptable.

3. Review and record the documentation

Examine the documentation using a review method permitted under current I-9 rules. Documents must reasonably appear genuine and relate to the employee presenting them.

In Supplement B, enter the required document information, including the document title, number, and expiration date, if any. Complete the employer certification and date it accurately.

When using a separate Supplement B, enter the employee’s name as instructed and retain it with the employee’s original Form I-9. If the original I-9 is an older edition, consult current instructions for using the current Supplement B with that record.

4. Address late or unresolved cases promptly

Do not backdate a reverification entry to make it appear timely. Complete required actions accurately and document corrections according to USCIS guidance.

If the employee cannot establish continued work authorization by the applicable deadline, escalate immediately to the designated HR compliance lead or qualified immigration counsel. Employers cannot continue employing someone they know lacks employment authorization.

How should HR handle automatic extensions?

Some employees may have employment authorization or documentation automatically extended under applicable rules. Depending on the situation, supporting evidence might include an expired document together with a qualifying receipt notice or other specified evidence.

Extension eligibility can depend on factors such as document category, filing timing, and the type of application. Temporary Protected Status-related extensions may require checking a specific government notice.

Build a standard escalation path for these cases:

• Identify the document category and supporting evidence.
• Check current USCIS guidance and any applicable official notice.
• Determine the correct extended deadline.
• Record the extension as USCIS directs.
• Preserve the supporting records and reset the reminder.

Because extension rules and notices can change, confirm current requirements rather than relying on an old spreadsheet formula.

Build a reverification workflow that scales

A useful tracking system distinguishes actual reverification deadlines from document expirations that require no action.

Assign one owner to each case, with a backup for absences. Set advance reminders that give employees time to gather acceptable documentation, while making clear that reminders are not demands for a particular document.

Give HR a small set of clear statuses: review needed, extension under review, reverification completed, or escalation required. Restrict access to sensitive records and periodically check that alerts agree with the underlying I-9 documentation.

Reverification also should not automatically generate a new E-Verify case. E-Verify is not used to reverify existing employees’ employment authorization.

Trak’s Form I-9 and E-Verify services can help employers strengthen the processes surrounding verification and ongoing compliance.

This article provides practical information, not legal advice. Confirm current USCIS requirements and seek qualified counsel for employee-specific questions.

Need a more consistent process for I-9 deadlines and documentation? Contact Trak Services to discuss your workflow.