What Is the Issuing Authority on a U.S. Passport for Form I-9?
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Onboarding screens get their name fields from payroll more often than anyone admits. Payroll truncates at 20 characters, so Garcia Lopez becomes Garcia before Section 1 is even open. The same module will not save a blank Middle Initial, which is how N/A ends up in a box USCIS never asked you to fill. By the time E-Verify rejects the case, someone has usually already edited the I-9 to match the error message instead of the passport.
Form I-9 has no character limit on names. E-Verify's case creation does, and most HCM vendors treat that payload cap as if it were an I-9 rule. Section 1 carries the employee's current legal name exactly as it appears on their work authorization documents. When a name is too long for the E-Verify case, you shorten or remap what you send in the payload and leave the form alone.
Section 1 is the employee's attestation of their current legal name. U.S. Citizenship and Immigration Services (USCIS) writes the rules in the M-274, Section 3.0. Keep hyphens and apostrophes where the documents show them. If someone has two last names, both go in Last Name. A person with one name writes it in Last Name and puts Unknown in First Name.
E-Verify runs later, checking what you typed against Social Security Administration and Department of Homeland Security records. It reads a case you create from the I-9. It does not replace the I-9 or get to rewrite what Section 1 says. When a name is too long for the case, the I-9 is still the record ICE will pick up in an inspection.
The handbook is short on this, which is why electronic systems keep inventing rules the paper form never had.
| Field | Enter | If they do not have one |
|---|---|---|
| Last Name (Family Name) | Current legal last name. Both names if they have two (Garcia Lopez, Smith-Johnson, De La Cruz, O'Neill). | They always have a last name on this form. A one-name person puts that name here. |
| First Name (Given Name) | Current legal first name. Both names if they have two (Mary Jo, John-Paul, Tae Young, D'Shaun). | Type Unknown. A blank and N/A both fail this field. |
| Middle Initial | The initial, if they have a middle name. | Leave it blank. USCIS says you may. |
| Other Last Names Used | Maiden name or any other legal last name they have used. | Leave it blank. USCIS says you may. |
If they later change their legal name, that is Supplement B, not a new I-9. Walkthrough: I-9 name change.
N/A is for the work-authorization expiration date when the employee checks that they are a noncitizen authorized to work and that authorization does not expire. Asylees and refugees land here a lot. The EAD article covers the rest of that checkbox: EAD card for I-9.
Chatbots keep telling people to put N/A in every empty name box, usually with a fine attached. That is not what the handbook says, and it is not what ICE's March 2026 inspection fact sheet says either. N/A does not stand in for a missing first name, and you are not required to stamp it into Middle Initial or Other Last Names Used when those fields simply do not apply.
ICE's March 16, 2026 fact sheet treats failure to complete the printed or typed legal name in Section 1 as a substantive violation. Missing "other last names used" (when they had one) is still a technical failure, with a 10-business-day cure. A blank middle initial on someone who never had a middle name is not a trap. Paperwork range if you do get it wrong: $288–$2,861 per form (January 2, 2025 Federal Register). Full table: 2026 I-9 penalties.
The public E-Verify user manual does not print a name-length cap, but the cap shows up the moment you try to create a case. SAP Knowledge Base Article 3701091 calls it a known E-Verify limit: first_name must be 25 characters or fewer. Mitratech's Tracker FAQ says USCIS E-Verify Support imposes 25 characters on all name fields, and that extra names can be moved to Other Names on the case.
Some HCM screens still advertise last name up to 40 characters. Treat 25 as the number that actually rejects a case, even if your payroll field happily lets you type 40.
E-Verify will take letters, spaces, hyphens, and apostrophes, so O'Neill and Smith-Johnson can stay intact. Periods, commas, and a "Jr." stuffed into Last Name are what usually fail. Do not strip the hyphen on the I-9 to please the case; strip it only in the payload if E-Verify rejects that character, and only after you have looked at the documents.
| Name in one field | Characters | E-Verify case |
|---|---|---|
| Maria-Alejandra Rodriguez | 25 | Fits |
| Juan Carlos Gomez Ramirez | 25 | Fits |
| Jean-Christophe de-la-Vega | 26 | Rejects until shortened |
| Christopher-John-Alexander | 26 | Rejects until shortened |
The I-9 keeps the legal name even when it runs 32 characters, while the E-Verify case can send a shortened string so the case submits. Do not cap the I-9 field at 25 "so they match." ICE reads the form; E-Verify reads the case. ICE also wants the employee's complete name at the top of Section 2, and chopping it there to match a 25-character case is a technical failure on the March 2026 fact sheet.
If you have to shorten the payload, show the operator what you are sending. Silent truncation is how you get a Tentative Nonconfirmation when SSA has Garcia Hernandez and you sent Garcia Hernan. Tracker-style guidance from E-Verify Support is to move overflow into the case's Other Names field after looking at the documents, which is fine for the case. Do not invent a maiden name on Section 1 to make the character count work; Other Last Names Used on the I-9 is a legal-history field, not an overflow bucket.
"The systems we audit keep chopping the last name on the I-9 so the E-Verify button will light up," says Patricia Duarte, Director of Compliance at i9 Intelligence. "Wrong document. Leave the legal name on the form. Shorten the payload, and leave a note of what you actually sent. Six months later nobody remembers why Lopez disappeared off the end."
That is a configuration problem, not an I-9 instruction. If the last-name field in your onboarding module was copied from payroll, it will keep losing Garcia Lopez even when the passport shows the full string. ATS auto-fill of Section 1 is its own trap: HCM Section 1 auto-fill. Book a free compliance call and we will tell you whether the I-9s you already have are truncated, or only the cases.
The one-name hire gets N/A in First Name because the screen required a value and N/A was in a dropdown, even though USCIS wanted Unknown. A hyphenated last name gets split, the second half dropped so E-Verify will take it, and then that shortened version is what prints on the I-9. Someone puts Jr. in Last Name because payroll had a suffix field and the I-9 did not. Middle Initial gets N/A in red because a vendor treated every blank as an error. If your electronic I-9 will not save a blank middle initial, N/A in that one box is a software workaround, not a Form I-9 instruction, and it still does not belong in First Name.
The other pattern we see is copying a 20-character payroll last name onto Section 1 and calling it done. Payroll can truncate. Form I-9 cannot. If the documents show a longer legal name than the HRIS stored, the I-9 follows the documents, not the HRIS.
No. M-274 Section 3.0 tells you what to enter and never caps the length. If your software refuses a 30-character last name, that is a vendor choice, not a USCIS rule.
Put that name in Last Name and type Unknown in First Name. That is the USCIS instruction for employees who do not use a Western given-name-plus-family-name pattern, and we see HR teams stumble on it most often with international hires whose documents list a single legal name.
For first name, no: use Unknown, and only when the employee truly has one name. Middle initial and other last names can stay blank when they do not apply. N/A belongs in the work-authorization expiration date when that authorization does not expire.
Usually one name field in the case is over 25 characters, or a period, comma, or suffix snuck in from payroll. The I-9 can still be correct. Shorten or remap the payload, confirm it against the documents, and submit the case without going back to erase letters on the form just so the two screens look identical.
On the E-Verify case, Support has told vendors they can move overflow into Other Names after reviewing the documents. On the I-9 itself, Other Last Names Used is only for last names the employee has actually used in the past. Do not manufacture a maiden name to dodge a character limit.
Not on the March 2026 fact sheet. Missing the legal name in Section 1 is substantive; missing other last names used when they had one is still technical, with a cure window. Blank is correct when they have never used another last name. More on the line: ICE redefines substantive I-9 violations.
When the I-9 already has the legal name and the case still will not create, you are looking at a payload problem, not a form problem. Call before anyone edits Section 1 to match whatever the error message showed.
Call us at (713) 668-6200 (Mon–Fri, 8 AM – 5 PM CT), email support@i-9intelligence.com, or submit a ticket.
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