Who Can Be an I-9 Authorized Representative?

An employee accepts an offer, but the nearest company office is hundreds of miles away. Who can examine the employee’s documents and complete Section 2 of Form I-9?

An employer may designate an authorized representative to perform that work on its behalf. The representative does not have to be an employee of the company. However, the employer remains responsible for violations connected with the form or verification process.

For organizations hiring across many locations, that distinction matters: delegating the appointment is not the same as transferring compliance responsibility.

Who can serve as an I-9 authorized representative?

U.S. Citizenship and Immigration Services allows employers to designate a person to act on their behalf when completing Form I-9. Examples include personnel officers, foremen, agents, and notaries public.

Depending on the employer’s procedures, a representative might be:

• A manager at another company location.
• A designated individual working through a verification service.
• A local professional who agrees to perform the examination.
• A friend or family member of the employee whom the employer authorizes.

An employee cannot act as their own authorized representative. The employee completes Section 1, while the employer or its representative performs the employer’s responsibilities in Section 2.

USCIS does not require a particular agreement or document to establish the designation. Still, written instructions and a record of whom the employer authorized are useful operational controls. An employee suggesting a convenient reviewer should not replace the employer’s designation process.

Does the representative need to be a notary?

No. Form I-9 does not require notarization, and the representative does not need a notary commission simply because they are completing the form.

When a notary serves as an authorized representative, they are acting in that representative capacity—not notarizing the employee’s signature. They should not affix a notary seal to Form I-9.

State rules may affect whether a notary or another service provider can perform this work. Confirm applicable requirements before making notaries your standard solution across multiple states.

What does the authorized representative actually do?

For a standard physical examination, the representative meets with the employee in person, examines acceptable original documents, and completes and signs Section 2. A certified copy of a birth certificate is an exception to the general original-document requirement; certain receipts may also be acceptable under specific rules.

The representative must determine whether the documents reasonably appear genuine and relate to the person presenting them. They are not expected to be a forensic document expert.

The employee chooses which acceptable documents to present: either one List A document, or one List B document together with one List C document. The representative should not demand a passport, green card, or other preferred document.

For employers participating in E-Verify, a List B document must contain a photograph.

Who signs Section 2?

The person who actually performs the document examination completes and signs the employer certification. An HR employee should not sign as though they examined documents when a local representative performed the examination instead.

Give the representative the employer’s correct business name and address, the employee’s first day of employment, and instructions for completing the remaining employer fields. These are details an outside reviewer may not know.

Does using a representative permit video inspection?

Not by itself. Designating someone as an authorized representative does not create permission to examine documents over a video call.

Under the standard process, the employee and representative meet in person. The company’s HR team can be elsewhere; the required physical examination happens locally.

A separate DHS-authorized alternative procedure allows qualifying employers to examine documents remotely when they satisfy its conditions. That procedure has its own eligibility, examination, and recordkeeping requirements. See our guide to the remote I-9 inspection alternative procedure before choosing that route.

Keep these workflows distinct. An emailed document image followed by a casual video call is not a substitute for either compliant process.

What deadlines still apply?

Using an authorized representative does not extend the Form I-9 deadlines.

The employee generally must complete Section 1 no later than their first day of employment for pay. The employer or representative generally must complete Section 2 within three business days after that first day.

If the employee is hired for fewer than three business days, Section 2 must be completed no later than the first day of employment.

Schedule the appointment early enough to resolve a missed meeting or a question about acceptable documents. Do not wait until the deadline to find out whether the proposed representative is available and willing to sign.

A practical workflow for employers hiring at volume

1. Designate the reviewer before the appointment

Record who will act as the representative and how HR can reach them. Confirm that the person understands the assignment and can complete it within the required timeframe.

Avoid sending employees out with only the instruction to “find someone who can notarize your I-9.” That describes the task incorrectly and invites delays.

2. Provide a short instruction packet

Include:

• The current Form I-9 and its instructions, or access to your electronic workflow.
• The Lists of Acceptable Documents.
• The employee’s start date and Section 2 deadline.
• Employer information needed to complete the certification.
• A contact for document and process questions.
• Secure submission instructions.

Explain that the employee chooses the documents and that unclear situations should be escalated rather than improvised.

3. Define document-copying requirements

Tell representatives whether document copies must be retained under your applicable process. Some procedures, including the DHS alternative procedure and certain E-Verify situations, require copies.

Where copying is discretionary, establish and consistently apply a policy without discrimination. Keeping copies does not replace completing Form I-9.

4. Review the completed record promptly

Check for missing signatures, incomplete document information, incorrect employer details, and discrepancies in the start date. Resolve errors transparently; never backdate a signature or make an undocumented alteration.

Centralized Form I-9 verification support can help employers coordinate local reviewers while maintaining a consistent oversight process.

5. Protect employee information

Use an employer-approved transmission and storage method. Representatives should not retain document images in personal email, phone galleries, or other uncontrolled locations after the authorized work is finished.

Make the handling instructions clear before documents are collected, not after they have been shared.

Delegation works best with clear ownership

An authorized representative can make distributed hiring more practical, but HR should still own designation, deadlines, instructions, quality review, and recordkeeping.

Before implementing a process, confirm current requirements in USCIS’s Form I-9 instructions and Handbook for Employers, along with applicable state restrictions. This article provides practical guidance, not legal advice.

Need a more consistent authorized-representative workflow? Contact Trak Services to discuss support for your Form I-9 process.