Executive Order No. 15 Iowa: I‑9 & E‑Verify Compliance

Executive Order No. 15 Iowa: I‑9 & E‑Verify Compliance

On October 8, 2025, Executive Order No. 15 Iowa was issued by Governor Kim Reynolds, dramatically shifting the landscape of employment eligibility and professional licensing in the state. This executive action mandates that every executive branch agency and the Iowa Board of Regents use E-Verify to confirm employment eligibility and the SAVE Program to validate immigration or citizenship status before issuing any state-issued professional or occupational licenses.

This directive arrives in response to a high-profile case involving Des Moines Public Schools Superintendent Ian Roberts, who was arrested for being unlawfully present in the U.S. despite holding a leadership position in Iowa’s public education system. The case brought national scrutiny to Iowa's vetting processes and accelerated political momentum behind mandatory work eligibility verification.

Overview of Executive Order No. 15

Executive Order No. 15 requires that all state agencies and the Board of Regents:

• Use E-Verify to confirm employment eligibility for every new hire.
• Use the Systematic Alien Verification for Entitlements (SAVE) program to confirm citizenship or immigration status before granting a professional license.
• Cooperate with a newly established SAVE Clearinghouse, which streamlines SAVE queries for state agencies.

The order specifically aligns Iowa with federal immigration laws under 8 U.S.C. §1621, §1611, and other PRWORA statutes, ensuring state programs do not provide public benefits to individuals who are not legally eligible.

‍

Why the Order Was Issued

The Roberts case highlighted a critical failure in verifying employment eligibility, as he had allegedly provided falsified documents, including a Social Security card, to complete his Form I-9. E-Verify, had it been used, would have flagged expired work authorization and likely prevented his hiring. The situation prompted calls from Iowa legislators for mandatory E-Verify use, especially in public employment and state licensing bodies.

Governor Reynolds cited the Roberts case directly: “This executive action... will verify the legal immigration or citizenship status for anyone requesting a state-issued professional license before they provide services for Iowans.”

‍

Compliance Requirements Under Executive Order 15

1. Mandatory Use of E-Verify: All Iowa executive branch agencies and the Board of Regents must now:

• Enroll in E-Verify.
• Use it for every new hire moving forward.
• Maintain documentation in compliance with Form I-9 regulations.

2. Licensing Verification via SAVE: Before issuing a license, agencies must:

• Verify U.S. citizenship or eligible immigration status using SAVE.
• Rely on the SAVE Clearinghouse to manage queries across departments.

3. No Licenses Without Verification: Licensing agencies are prohibited from granting professional or occupational licenses unless citizenship or immigration status is confirmed.

4. Non-Discrimination Clause: The order reaffirms that enforcement must avoid discrimination based on race, religion, gender, or national origin.

‍

Implications for State Agencies and Licensing Boards

Agencies must:

• Review and update internal hiring policies.
• Formalize MOUs with USCIS to access SAVE.
• Cooperate with the SAVE Clearinghouse.
• Ensure HR and licensing staff are trained on E-Verify and SAVE protocols.

This impacts entities like:

• Iowa Medical Board
• Iowa Board of Nursing
• Iowa Real Estate Commission
• Board of Regents institutions (e.g., University of Iowa)

‍

What Employers, HR Teams, and Applicants Should Know

For HR Teams:

• Ensure Form I-9 processes align with federal rules.
• Use E-Verify promptly after hire (within three business days).
• Prepare for possible system outages; keep records of attempted verifications.

For Applicants:

• Be prepared to provide lawful documentation of citizenship or immigration status.
• Understand that even previously granted licenses may be scrutinized upon renewal.

‍

Building a Compliant Hiring and Licensing Process

Compliance with Executive Order No. 15 requires an integrated approach:

• Form I-9 Review: Confirm all documentation is genuine, unexpired, and appropriately matched.
• E-Verify Enrollment: If not already enrolled, employers must register and train staff.
• SAVE Integration: Agencies should initiate MOUs with USCIS and test the SAVE process.
• Recordkeeping: Retain all E-Verify case records and SAVE confirmations with licensing or hiring files.
• Training: All compliance staff should be trained in both systems and updated on anti-discrimination practices.

‍

Legal Challenges and Future Outlook

While Executive Order No. 15 aligns with federal law, its aggressive implementation may invite legal scrutiny, particularly over access and privacy. Critics have voiced concern over:

• Potential discrimination against immigrant communities.
• Barriers to licensure for foreign-trained professionals.

Still, momentum is growing. State Senator Julian Garrett has pledged to reintroduce legislation requiring E-Verify for all employers, citing Roberts’ case as a legislative catalyst.

‍

Raising the Bar for Compliance in Iowa

Executive Order No. 15 represents a defining shift in how Iowa enforces immigration-related hiring and licensing practices. By mandating the use of E-Verify and SAVE across all executive agencies, the state sets a new precedent for compliance and risk management.

Agencies and HR teams must view this not just as a legal requirement, but as an opportunity to tighten internal controls, prevent future oversight failures, and build public trust in employment and licensing practices.

Your Action Plan:

• Audit all current I-9 and E-Verify processes to identify gaps.
• Enroll in E-Verify if your agency isn’t already registered. For help, visit our E-Verify compliance center.
• Initiate a Memorandum of Agreement with USCIS to gain access to the SAVE Program.
• Train HR, legal, and licensing staff to prevent errors and ensure ongoing compliance.
• Read our in-depth article on the Ian Roberts case and its compliance implications to understand the real-world impact of inadequate verification protocols.

‍

Agencies that take these steps will be well-positioned not only to meet the current requirements but to withstand future scrutiny in an evolving regulatory landscape.