Why Storing Form I-9s in More Than One System Is a Compliance Risk
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Form I-551 is the official name for the United States Permanent Resident Card — the document most people call a "green card." If you work in HR or handle Form I-9 verification, you will encounter this document regularly. It is one of the most common List A documents presented during the I-9 process, and it is also one of the most frequently mishandled.
This guide explains what Form I-551 is, what the I-551 stamp means, where to find the document number, and exactly how to record a permanent resident card in Section 2 of Form I-9. Whether you are an HR professional completing an I-9 for the first time or an experienced compliance officer looking for a quick reference, this page has what you need.
Form I-551 is the permanent resident card issued by U.S. Citizenship and Immigration Services (USCIS) to individuals who have been granted lawful permanent resident (LPR) status in the United States. The "I-551" designation is the USCIS form number — it is printed on the card itself.
The permanent resident card is commonly known as a "green card." The nickname dates back to the original version of the card, which was printed on green paper. Modern cards are not green — they use a white and blue design with multiple security features — but the name has stuck.
Is Form I-551 the same as a green card? Yes. They are the same document. "Form I-551," "permanent resident card," and "green card" all refer to the same thing. USCIS uses "Form I-551" in official contexts. Everyone else says "green card."
A permanent resident card serves as proof that the holder has been authorized to live and work in the United States permanently. It contains the cardholder's photo, name, date of birth, Alien Registration Number (A-Number), USCIS number, category of admission, card expiration date, and a machine-readable zone on the back.
For I-9 purposes, the permanent resident card is a List A document. That means it establishes both identity and employment authorization on its own — the employee does not need to present any additional documents. For a full list of acceptable I-9 documents, see our guide to valid forms of ID for the I-9.
An I-551 stamp — also called an ADIT stamp — is a temporary endorsement placed in a foreign passport by USCIS or U.S. Customs and Border Protection (CBP). ADIT stands for Alien Documentation, Identification, and Telecommunication. The stamp serves as temporary evidence of lawful permanent resident status when the cardholder does not have a physical permanent resident card.
Common situations where someone may have an I-551 stamp instead of a card:
The I-551 stamp is typically valid for one year from the date it is placed in the passport, though some stamps may have shorter validity periods. The stamp includes the cardholder's A-Number and the expiration date.
I-9 relevance: A foreign passport containing an unexpired I-551 stamp (or an unexpired ADIT stamp) is a valid List A document for Form I-9 purposes. This is a separate document from the permanent resident card itself — meaning either one can be used, but they are recorded differently in Section 2.
The permanent resident card contains several different numbers, and this is where confusion starts. HR professionals frequently enter the wrong number on the I-9 because the card has multiple identifiers on both the front and back.
Here is what you will find on a current permanent resident card:
The critical distinction: When completing Section 2 of Form I-9, you need the 13-character document number from the back of the card — not the 9-digit A-Number from the front. This is one of the most common errors employers make, and it shows up as a finding in I-9 audits.
"When I review a client's I-9s before an audit, the green-card mistakes jump off the page," says Patricia, Director of Compliance at i9 Intelligence. "The A-Number on the front is easier to see — it's larger, at the top, starts with a letter — so people grab it and put it in the Section 2 Document Number field by reflex. ICE auditors look for this exact error first, and every I-9 with it counts as a paperwork violation."
Note: Older versions of the permanent resident card have a slightly different layout. If you encounter a card that looks different from current versions, the document number may be in a different location. When in doubt, look for the longest alphanumeric code on the card — that is typically the document number. For help verifying a specific document, call our compliance team.
When an employee presents a permanent resident card (Form I-551) during the I-9 process, you will record it in List A of Section 2. Here is exactly what to enter in each field.
Document Title: Enter "U.S. Permanent Resident Card" or "Form I-551." Either is acceptable.
Issuing Authority: Enter "USCIS" or "U.S. Citizenship and Immigration Services."
Document Number: Enter the 13-character alphanumeric document number from the back of the card. Do not enter the A-Number from the front.
Expiration Date: Enter the "Card Expires" date from the front of the card.
Because the permanent resident card is a List A document, you do not need anything in the List B or List C columns. The card alone satisfies the I-9 document requirement.
Yes. This is a critical point that many employers get wrong.
Lawful permanent resident status does not expire when the physical card does. The card has an expiration date, but the person's immigration status — their right to live and work in the United States — remains valid indefinitely (unless formally revoked through a legal proceeding).
Under the M-274 Handbook for Employers, USCIS guidance states that an expired permanent resident card is still an acceptable List A document for Form I-9. Employers who refuse to accept an expired permanent resident card, or who demand a different document instead, may be committing unfair immigration-related employment discrimination under Section 274B of the Immigration and Nationality Act (INA).
In practice, this means: if an employee presents an expired permanent resident card for the I-9, accept it. Record the expiration date as shown on the card. Do not ask them to bring a different document or to provide proof that they have renewed the card.
Note: USCIS has also extended the validity of permanent resident cards in certain situations. For example, the automatic extension of permanent resident cards to 24 months applies when a renewal (Form I-90) has been properly filed. If an employee presents a card with an I-797 receipt notice showing a pending I-90, the card's validity is automatically extended.
For more on how the I-9 document verification process works, see our guide: What Is a Form I-9?
Not sure how to handle a specific document? Our compliance team has 27+ years of I-9 and E-Verify expertise. We can walk you through any document question — no charge.
A foreign passport with an unexpired I-551 stamp (ADIT stamp) is a separate List A document from the permanent resident card. It establishes both identity and employment authorization, just like the card itself. However, you record it differently in Section 2.
Document Title: Enter "Foreign Passport with I-551 Stamp" or "Foreign Passport with ADIT Stamp."
Issuing Authority: Enter the name of the country that issued the passport (e.g., "Mexico," "Philippines," "India") — not USCIS. USCIS placed the stamp, but the passport was issued by the foreign government.
Document Number: Enter the passport number — not the A-Number from the I-551 stamp.
Expiration Date: Enter the expiration date of the I-551 stamp, not the passport expiration date. This is the date that matters for I-9 purposes, because the stamp is what proves employment authorization.
Unlike the permanent resident card (which remains acceptable even after expiration), the I-551 stamp has a hard expiration date. Once the stamp expires, it is no longer valid for I-9 purposes.
When an employee's I-551 stamp is approaching expiration, you will need to reverify their employment authorization using Supplement B (formerly Section 3) of Form I-9. At that point, the employee should present a new document — typically their physical permanent resident card, which should have arrived by then, or a new I-551 stamp.
Do not reverify early. You must wait until the stamp's expiration date to complete Supplement B.
There is a third way an employee can present evidence of permanent resident status for the I-9: through a machine-readable immigrant visa (MRIV) in their foreign passport.
When a new permanent resident enters the United States for the first time, they typically carry a foreign passport with an immigrant visa issued by a U.S. consulate. At the port of entry, U.S. Customs and Border Protection (CBP) stamps the passport with an admission endorsement. This endorsed MRIV serves as temporary evidence of permanent residence — it is a valid List A document for Form I-9 purposes.
The immigrant visa page in the passport usually contains the text: "UPON ENDORSEMENT SERVES AS TEMPORARY I-551 EVIDENCING PERMANENT RESIDENCE FOR 1 YEAR." However, according to USCIS guidance on temporary I-551 stamps and MRIVs, employers should treat the MRIV as an acceptable List A document valid for one year from the date of admission — even if the visa does not include the "FOR 1 YEAR" notation.
Document Title: Enter "Foreign Passport with Machine-Readable Immigrant Visa" or "Foreign Passport with MRIV."
Issuing Authority: Enter the name of the country that issued the passport.
Document Number: Enter the passport number.
Expiration Date: Enter a date one year from the date of admission (the date on the CBP admission stamp).
The CBP admission stamp does not need to be placed directly on the immigrant visa page. Per USCIS guidance, if the stamp is endorsed and is near but not on the immigrant visa, it is still a valid endorsement. Do not reject the document simply because the stamp appears on a different page of the passport.
These are different documents that serve a similar purpose:
Both are acceptable List A documents. Both expire. Both require reverification via Supplement B when the expiration date arrives.
Most permanent resident cards follow a predictable format. A few don't — and these are the situations where HR teams call us.
A conditional permanent resident receives a 2-year card instead of the standard 10-year card. The category code typically starts with "CR" (for example, CR1, CR6) rather than "IR" (IR1, IR5). Record this card exactly like a standard I-551 — List A, 13-character document number from the back — but watch for expiration. If the employee files Form I-751 (Petition to Remove Conditions) and presents a Form I-797 receipt notice alongside the expired conditional card, that combination is an acceptable List A document per USCIS guidance. Record the I-797 expiration date as the document expiration in Section 2.
Cards issued before May 2010 use an older layout where the document number may be in a different location — sometimes along the side or bottom of the back. If you encounter a card that looks different from current designs, look for the longest alphanumeric code on the card; that is typically the document number. Older cards that are still within their expiration date (or expired, per the rules above) remain valid List A documents.
An employee who became a U.S. citizen still has their old green card in a drawer somewhere. If they present it for a new-hire I-9, ask them about their current citizenship status before accepting it — a U.S. citizen should identify as one in Section 1, not as a lawful permanent resident, and should present different documents (U.S. passport, Certificate of Naturalization, or List B + List C combination). If they've already completed Section 2 with the green card from an earlier hire and you later learn they've naturalized, do not reverify — you cannot compel reverification of a Form I-551, and the original I-9 remains valid.
An employee presents a foreign passport with a valid, unexpired I-551 stamp — but the passport itself has expired. This is still a valid List A document. Per USCIS guidance, the I-9 concerns itself with the stamp's validity, not the passport's. Record the passport number in the Section 2 Document Number field and the I-551 stamp's expiration date (not the passport's) as the document expiration.
These are the errors we see most often when employers handle permanent resident cards during the I-9 process. Every one of them can result in a finding during an I-9 audit.
As explained above, permanent resident status does not expire when the card does. Refusing to accept an expired card — or asking the employee to bring a replacement — may violate anti-discrimination provisions under the INA. Accept the card, record the expiration date, and move on.
The A-Number (Alien Registration Number) is the 9-digit number on the front of the card. The document number is the 13-character code on the back. Section 2 asks for the document number. This mix-up is extremely common and is one of the first things ICE auditors check.
You cannot request that an employee present a specific document for the I-9. Under the anti-discrimination provisions of the INA, the employee chooses which acceptable documents to present from List A, B, or C. You may not say "bring your green card" — even if you know the employee is a permanent resident. If they choose to present a driver's license (List B) and an unrestricted Social Security card (List C), you must accept that combination.
Some HR professionals are not aware that a foreign passport with an I-551 stamp — also called an ADIT stamp — is a valid List A document. If an employee presents a foreign passport, check for an I-551 or ADIT stamp inside. If the stamp is present and unexpired, the passport qualifies as a standalone List A document — no additional documents needed.
Let our team handle document verification for you. With i9 Intelligence's remote I-9 verification, our trained authorized representatives complete Section 2 via video call. We review the documents, fill in the fields correctly, and ensure compliance — so your HR team doesn't have to second-guess every card and stamp that comes across the desk.
When ICE conducts a Notice of Inspection audit, the I-551 errors above turn into line items on the findings letter. Each error is a substantive or technical paperwork violation, and each one carries a per-form fine.
Example: a 50-employee construction firm. During a routine audit, the ICE auditor flags 12 Forms I-9 where the employer entered the A-Number from the front of the green card in the Section 2 Document Number field. Under the current fine schedule (2025 Federal Register adjustment, 8 CFR § 274a.10), each substantive paperwork violation carries a fine of $288 to $2,861 per Form I-9. At a midpoint of about $1,200 per form, that single error type alone is $14,400 in paperwork fines — even if every one of those employees is fully authorized to work.
Pair that with three other routine errors (expired cards that weren't properly recorded, missing I-551 stamp endorsements, foreign-passport-with-stamp documents where the issuing authority was recorded as "USCIS" instead of the country that issued the passport) and the same 50-employee audit routinely hits $20,000 to $40,000 in paperwork fines — before any knowing-hire penalties are considered. The full fine schedule, including the $716 to $5,724 per-worker knowing-hire range, is in I-9 Penalties in 2026.
Note: ICE auditors work from a checklist. If multiple I-9s show the same error pattern — every green-card form has the A-Number in the wrong field, every expired card is missing documentation — expect every one of those forms to be flagged. There's no partial credit for making the same mistake consistently.
A self-audit catches these patterns before ICE does. Our team runs self-audits for clients ahead of anticipated Notices of Inspection. Learn about our I-9 audit services.
The I-551 is one of many USCIS forms that employees may reference or present during the I-9 process. Here is a quick reference comparing the documents that cause the most confusion.
| Document | Form Number | What It Is | Valid for I-9? |
|---|---|---|---|
| Permanent Resident Card (Green Card) | I-551 | Proof of lawful permanent resident status | Yes — List A |
| Foreign Passport with I-551 / ADIT Stamp | I-551 stamp | Temporary proof of permanent resident status | Yes — List A (stamp must be unexpired) |
| Foreign Passport with Machine-Readable Immigrant Visa (MRIV) | Immigrant visa + CBP stamp | Temporary I-551 evidence for new arrivals | Yes — List A (valid 1 year from admission) |
| Employment Authorization Document (EAD) | I-766 | Proof of temporary work authorization | Yes — List A |
| Arrival/Departure Record | I-94 | Proof of lawful admission to the US | Not by itself |
| Notice of Action | I-797 | Receipt for a pending USCIS application | Limited — receipt rule only |
| Certificate of Eligibility (Student) | I-20 | Status document for F-1 students | No |
Key distinction: The I-551 (permanent resident card) and the I-766 (EAD) are both List A documents, but they represent different immigration statuses. The I-551 is for permanent residents. The I-766 is for people with temporary work authorization (such as TPS holders, asylum applicants, or certain visa holders). They are recorded the same way in Section 2, but they have different implications for reverification.
If an employee mentions a form number and you are not sure whether it is acceptable, consult the USCIS list of acceptable documents or call our compliance team.
Yes. Form I-551 is the official USCIS form number for the permanent resident card, which is commonly known as a green card. The designation "I-551" is printed on the card itself. "Form I-551," "permanent resident card," and "green card" all refer to the same document.
The document number is a 13-character alphanumeric code on the back of the card, typically located below the magnetic stripe. Do not confuse it with the 9-digit A-Number (Alien Registration Number) on the front of the card. When completing Section 2 of the I-9, enter the 13-character document number from the back.
Yes. Lawful permanent resident status does not expire when the physical card does. An expired permanent resident card remains an acceptable List A document for Form I-9. Rejecting an expired permanent resident card may constitute unfair immigration-related employment discrimination under Section 274B of the Immigration and Nationality Act.
An ADIT stamp (also called an I-551 stamp) is a temporary endorsement placed in a foreign passport by USCIS or CBP as proof of lawful permanent resident status. A foreign passport with an unexpired I-551 or ADIT stamp is a valid List A document for Form I-9 verification. Unlike the permanent resident card, the stamp does have a hard expiration date — once it expires, it is no longer acceptable.
Enter the 13-character alphanumeric document number from the back of the card. Do not enter the 9-digit USCIS Number or A-Number from the front. This is one of the most common errors found during I-9 audits.
If you have questions about permanent resident cards, I-551 stamps, or any other document that comes up during the I-9 process, our compliance team is here for you.
Call us at (713) 668-6200 (Mon-Fri, 8am-5pm CT), email support@i-9intelligence.com, or submit a ticket.