The 2026 Midterms and Form I-9: What Changes for Employers, and When
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A Certificate of Naturalization is acceptable for Form I-9, but only as a List C document. It proves the employee can work in the United States and doesn't prove who they are, so the employee also needs a List B identity document, such as a state driver's license, to complete Section 2. The USCIS Handbook for Employers (M-274), Section 13.3 lists Form N-550 and its replacement, Form N-570, under List C item 7.
The error we find most often is the certificate written under List A with nothing beside it. That file has no proof of identity, and ICE counts a missing List B document as a substantive violation even when the employee is a U.S. citizen. It takes a few minutes to fix at hire and a lot longer to explain during an inspection.
The certificate used to be a List A document. The 1996 immigration law (IIRIRA) cut the number of documents employers could accept, and a 1997 INS interim rule took the Certificate of Naturalization and the Certificate of U.S. Citizenship off List A, but the form itself kept listing them for another ten years. The Federal Register notice from November 26, 2007 explains that USCIS finally removed both certificates from List A in the June 5, 2007 edition, which became the only valid version of the form on November 7, 2007.
Every edition since then has treated the certificate as List C. Old I-9s in your files may still show it under List A from the years before that change, and managers who trained on those forms tend to repeat the habit on new hires.
Both citizenship certificates work the same way on Form I-9, and so do their replacements. The difference from a U.S. passport is the second document.
| What the employee shows | Form I-9 list | Also needed |
|---|---|---|
| Certificate of Naturalization (Form N-550) | List C | One List B identity document |
| Replacement Certificate of Naturalization (Form N-570) | List C | One List B identity document |
| Certificate of U.S. Citizenship (Form N-560) | List C | One List B identity document |
| Replacement Certificate of Citizenship (Form N-561) | List C | One List B identity document |
| U.S. passport or passport card | List A | Nothing else |
A state driver's license or ID card is the usual List B pairing, but the employee picks from the whole Lists of Acceptable Documents. Naturalized citizens don't have to use the certificate at all, and a license with an unrestricted Social Security card works for them the same as for anyone else. Employers using E-Verify can require that the List B document have a photo, and that's the only condition they can add.
The certificate goes in the List C column, and the identity document goes in List B. For the certificate itself, enter these four fields.
In Section 1, a naturalized employee checks "A citizen of the United States." That box doesn't ask for an A-Number, so the number printed on the certificate doesn't go anywhere on the form. The A-Number field is for permanent residents and noncitizens authorized to work.
An I-9 with a certificate in List A and an empty List B is missing its identity document, and an ICE auditor will read it that way. Our I-9 audit team finds these across your active files and walks you through correcting each one before an inspection notice arrives.
The List A entry is the big one, and the other common one runs the opposite direction. A manager knows a new hire was born abroad and asks to see the naturalization certificate, or asks for a passport after seeing the certificate. DOJ's Immigrant and Employee Rights Section (IER) says asking an employee who marked "U.S. citizen" to present a naturalization certificate or a U.S. passport could be unlawful discrimination. The employee chooses the documents, and a citizen who hands you a license and a Social Security card owes you nothing more.
Smaller misses show up too. Some teams turn away a replacement N-570 or an older INS certificate because it looks unfamiliar, and IER specifically warns against rejecting valid documents because they're unfamiliar or an older version. Others accept a photocopy, though Section 2 requires the original. A few set a reverification reminder off the certificate, which never applies to a U.S. citizen.
"The certificate covers half of Section 2," says Patricia Duarte, Director of Compliance at i9 Intelligence. "We tell managers to show the employee the List B column and let them pick, instead of asking for a driver's license by name. Naming the document is where a good intention turns into a discrimination complaint."
E-Verify has a mismatch type that mostly affects naturalized citizens. The case result reads "SSA was unable to confirm U.S. citizenship," and E-Verify's Further Action Notice tells the employee they may not need to visit Social Security at all. With a Naturalization Certificate Number, A-Number, or USCIS Number, they can resolve it by calling DHS at 888-897-7781.
The E-Verify User Manual, Section 3.3.2 gives the employee eight federal government working days after referral to call DHS or visit an SSA office. Keep them on the schedule while the case is open, because employers can't take adverse action over a pending case. Our guide to handling an E-Verify mismatch walks through the notice and referral steps.
The certificate doesn't trigger E-Verify photo matching. Only four List A documents do, the U.S. passport, passport card, green card, and EAD.
Yes, as a List C document that proves employment authorization. The employee also has to present a List B identity document, such as a driver's license or state ID card.
No. It came off List A when USCIS released the June 5, 2007 edition of Form I-9, and every edition since lists it under List C.
Yes, on the same terms. Form N-560 and its replacement, Form N-561, are List C documents and need a List B document alongside them.
It doesn't, so enter N/A as the expiration date. U.S. citizens are never reverified, which means the certificate never comes back up in Supplement B.
Nowhere. A naturalized employee checks the U.S. citizen box in Section 1, and that box has no A-Number field, so you only record the certificate number in Section 2.
No. Asking a U.S. citizen for a naturalization certificate or passport could be unlawful discrimination under IER's guidance, so let the employee choose from the lists. The work authorization guide explains how each citizenship status maps to the documents.
Our compliance team has been reviewing citizenship certificates on Form I-9 for 28 years. Reach us here: