I-9 Preparer and Translator: When to Use Supplement A

An employee understands their work authorization status but needs help reading the English-language Form I-9. Another employee dictates answers while an onboarding coordinator enters them. Both situations raise the same question: does the person helping need to complete a certification?

Anyone who helps an employee complete Section 1 as a preparer or translator must complete Supplement A, Preparer and/or Translator Certification for Section 1. The employee must still sign Section 1 personally.

For employers hiring at volume, this requirement is easy to miss when assistance happens informally. A clear process helps HR capture the certification without discouraging employees from getting help.

What Is Form I-9 Supplement A?

Supplement A documents assistance with Section 1, Employee Information and Attestation. It is part of the Form I-9 materials available from U.S. Citizenship and Immigration Services.

Section 1 contains the employee’s identifying information and citizenship or immigration status attestation. A preparer or translator may help complete that section, but the assistance must be disclosed through the supplement.

Supplement A is not the same as Supplement B. Supplement B addresses reverification and rehire situations; Supplement A records who helped the employee complete Section 1.

If an employee completes Section 1 without assistance, Supplement A is not required. Employers do not need to create a completed certification simply because HR provided the form or monitored onboarding progress.

Who Counts as a Preparer or Translator?

The requirement depends on what someone does, not their job title or relationship to the employee.

A preparer or translator could be:

• An HR coordinator who enters the employee’s answers into Section 1.
• A supervisor who translates Section 1 questions and instructions.
• A coworker who helps the employee complete the section.
• A family member or friend who provides preparation or translation assistance.
• An interpreter engaged to support onboarding.

An employee does not have to complete Section 1 without help. However, the person assisting must document their involvement rather than treating it as an invisible part of onboarding.

Does ordinary HR support require Supplement A?

Providing a link to Form I-9, sending a reminder, or explaining where to find the form is different from preparing or translating Section 1.

Focus on the actual assistance provided. If an HR representative enters answers for the employee or translates the section so the employee can complete it, that representative is acting as a preparer or translator.

Avoid a blanket assumption that either every HR interaction requires certification or no HR employee ever needs to certify. Train staff to recognize preparation and translation assistance, and refer uncertain situations to the current USCIS instructions or qualified counsel.

How to Complete Supplement A

Build the certification into the same workflow as Section 1 rather than trying to reconstruct who helped weeks later.

1. Identify everyone who assisted

Ask whether anyone helped prepare or translate Section 1, including people outside the company. An employee may arrive with the section already completed after receiving help at home.

If more than one person assisted, each preparer or translator must complete a separate certification area. Do not have one person sign on behalf of the entire group.

2. Connect the supplement to the employee

Enter the employee’s name in the designated fields at the top of Supplement A. This is especially important when paper forms are scanned or when multiple onboarding documents are processed together.

Use additional Supplement A pages when needed to document all preparers and translators.

3. Have each helper complete their certification

Each preparer or translator must provide the information requested in their certification area, including their name, address, signature, and date.

The certification is an attestation about the assistance provided and the information in Section 1. An HR administrator should not sign it merely because they manage the onboarding process if someone else actually provided the assistance.

4. Obtain the employee’s own signature

A preparer or translator does not replace the employee as the person making the Section 1 attestation. The employee must personally sign Section 1, even when someone else helped enter or translate the information.

The employee must complete and sign Section 1 no later than their first day of employment for pay. Assistance does not extend that deadline.

5. Retain the supplement with Form I-9

Keep completed Supplement A pages with the employee’s Form I-9. If your system stores them as separate files, make sure they remain associated with the correct employee record and can be retrieved together.

Do not treat the certification as an optional attachment that can be discarded after onboarding.

Can the Same HR Representative Complete Section 2?

Yes. A person who assists with Section 1 may also act for the employer in completing Section 2.

These are separate responsibilities, however. Signing the employer certification in Section 2 does not satisfy the preparer or translator certification requirement for Section 1.

For example, an onboarding coordinator might type an employee’s dictated answers into Section 1, complete their own Supplement A certification, and then perform the employer’s Section 2 responsibilities. The employee still signs Section 1.

Trak Services’ Clear I-9 service can help employers manage the broader Form I-9 verification process as part of a consistent onboarding workflow.

What About the Spanish-Language Form I-9?

USCIS makes a Spanish-language Form I-9 available, but only employers in Puerto Rico may use it to meet the verification and retention requirements. Employers elsewhere in the United States must complete and retain the English-language form.

Outside Puerto Rico, the Spanish version may serve as a translation resource. If a person helps translate or prepare the employee’s English-language Section 1, that person must complete Supplement A.

Do not assume that providing a translated reference eliminates the need to document human assistance when it occurs.

Build a Reliable Supplement A Workflow

High-volume employers should make assistance visible without making it burdensome. A practical workflow includes:

• A clear question: Ask whether anyone helped prepare or translate Section 1.
• Named responsibility: Identify who will collect each helper’s certification.
• Separate signatures: Confirm that the employee and each preparer or translator sign in the correct places.
• Document association: Keep every completed supplement connected to the corresponding I-9.
• A review checkpoint: Check for missing certifications before closing the onboarding task.

For digital onboarding, verify that the platform supports multiple preparers or translators and preserves the required certifications. A general onboarding acknowledgment is not a substitute for Supplement A. Review the broader electronic I-9 requirements when evaluating your system.

Use the current USCIS form and instructions to confirm requirements before changing your process. This article provides practical information, not legal advice.

Need help making I-9 assistance and certification part of a consistent onboarding process? Contact Trak Services to discuss your workflow.