Remote I-9 Inspection: Rules for the DHS Alternative Procedure

Can employers inspect I-9 documents remotely?

Yes—but only through an authorized procedure. Eligible employers may use the Department of Homeland Security’s alternative procedure to examine Form I-9 documents remotely instead of conducting an in-person examination.

The alternative procedure is not simply permission to accept emailed documents or watch an employee hold up an ID on a video call. It combines document-copy review, live video interaction, specific recordkeeping, and participation in E-Verify.

Employers that do not qualify generally must arrange physical examination of original documents, including for employees who work entirely from home. An authorized representative can perform that examination on the employer’s behalf.

For high-volume hiring teams, the first decision is therefore not which video platform to use. It is whether the hiring site qualifies and which examination process will apply.

Who qualifies for the remote I-9 alternative procedure?

The alternative procedure is available to qualified employers enrolled in E-Verify and in good standing. Under DHS requirements, that includes employers that:

• Are enrolled in E-Verify for every U.S. hiring site using the alternative procedure.
• Use E-Verify to confirm employment eligibility for all newly hired employees at those participating sites.
• Comply with E-Verify program requirements, including applicable training requirements.
• Continue to participate in E-Verify and remain in good standing while using the procedure.

Using E-Verify at one location does not automatically make every location eligible for remote examination. Organizations with multiple entities, offices, or decentralized onboarding teams should verify how their enrollment and hiring sites are configured.

E-Verify also does not replace Form I-9. Employers still complete the form and satisfy its deadlines. Our guide to E-Verify versus Form I-9 explains the distinction.

Before implementing or changing a remote process, confirm current requirements through USCIS guidance on remote document examination. Forms, instructions, and program procedures can change.

How remote document inspection works

1. Let the employee choose acceptable documents

Provide the Lists of Acceptable Documents and let the employee select what to present: either a qualifying List A document or a qualifying combination of List B and List C documents.

Do not require a passport because it seems easier to review on camera. Do not request additional documents based on citizenship, immigration status, or national origin. For employers participating in E-Verify, a List B document must contain a photograph.

Give the employee clear instructions for securely submitting copies and attending the video interaction.

2. Examine copies before the video interaction

The employee must transmit copies of the documents they intend to present. If a document is two-sided, obtain copies of both sides.

Review the copies to determine whether the documents reasonably appear genuine. Confirm that images are clear and complete enough to examine and retain. A cropped identification card or unreadable image should trigger a request for a usable copy—not a request for a different document merely for convenience.

Use a secure submission method with limited access rather than scattering identity documents across recruiters’ inboxes.

3. Conduct a live video interaction

During the live interaction, the employee must present the same documents previously transmitted. Examine them to determine whether they reasonably appear genuine and relate to the employee presenting them.

A prerecorded video does not satisfy the live-interaction requirement. Neither does reviewing uploaded images without the live interaction.

The alternative procedure requires retention of document copies; it does not require recording the video call. Avoid collecting extra sensitive information without a clear business need and an appropriate privacy review.

4. Complete Form I-9 and indicate the procedure used

Complete the applicable employer portion of Form I-9 and check the box indicating that an alternative procedure authorized by DHS was used to examine documents.

For a new hire, Section 2 generally must be completed within three business days after the employee’s first day of work for pay. For employment lasting fewer than three business days, Section 2 must be completed no later than the first day of employment.

Remote examination does not extend these deadlines. Schedule document submission and the video interaction early enough to resolve missing images or technical problems.

5. Retain copies and complete the E-Verify process

Retain clear, legible copies of all documents examined under the alternative procedure, including both sides of two-sided documents, with the Form I-9 records. Those copies must be available if an authorized government official requests an inspection.

Create the required E-Verify case within the applicable deadline and follow current program instructions. Document inspection, Form I-9 completion, and E-Verify case handling are connected steps, but completing one does not automatically complete the others.

Can remote and onsite employees follow different processes?

Yes, within the rules governing consistent and nondiscriminatory use.

A qualified employer may choose to use the alternative procedure only for remote hires while physically examining documents for employees who work onsite or in a hybrid arrangement. That distinction must not be adopted for a discriminatory purpose or applied differently based on a protected characteristic.

Write down the operational rule. For example, a policy could identify which participating hiring sites use remote examination and which work arrangements receive physical examination.

An employee who is unable or unwilling to use the alternative procedure must be allowed to present documents for physical examination. Build that option into onboarding instructions rather than treating it as an exception managers must improvise.

What if your organization is not eligible?

A remote employee does not necessarily need to travel to headquarters. An employer may designate an authorized representative to physically examine documents and complete Section 2 on its behalf.

The representative must actually meet with the employee and examine the original documents. An ordinary video call is not a substitute for physical examination when the employer is not using an authorized alternative procedure.

Employers remain responsible for violations committed by their authorized representatives. Provide clear instructions, identify an escalation contact, and review the completed form promptly. Check applicable state restrictions when selecting a representative, particularly when considering a notary.

Build the workflow before the next hiring surge

A reliable remote process needs clear ownership at each handoff:

• Program owner: Confirms E-Verify eligibility and participating hiring sites.
• Onboarding coordinator: Sends document-choice instructions and schedules the live interaction.
• Reviewer: Examines copies, conducts the interaction, and completes the employer certification.
• Case owner: Creates and monitors the E-Verify case.
• Records owner: Confirms that required copies and forms are securely retained.

For larger teams, track incomplete submissions, approaching deadlines, and cases needing follow-up. Do not mark a hire’s compliance workflow complete simply because the video appointment occurred.

Trak Services’ Form I-9 verification and E-Verify services can help employers coordinate these steps across hiring teams.

This article provides practical information, not legal advice. Confirm current government requirements and consult counsel about organization-specific questions.

Need a more consistent remote-hiring process? Contact Trak Services to discuss your I-9 and E-Verify workflow.