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The issuing authority is the government office that issued the document, and on Form I-9 you write it in Section 2 right under the document title. For the documents HR sees every week, that means the state for a driver's license, SSA for a Social Security card, the U.S. Department of State for a U.S. passport, and USCIS for a green card or an Employment Authorization Document (EAD).
The field looks small, but ICE treats a missing issuing authority as a substantive violation. It's on the Section 2 list in the inspection fact sheet ICE revised on August 31, 2026, which means it can be fined per form if it's still blank when an inspection starts. The tables below cover every document on the Lists of Acceptable Documents, including the multi-document List A combinations most guides skip.
Most Section 2 entries come from these eight documents. Abbreviations are fine as long as they're widely understood, per M-274 Section 4.0.
| Document | Issuing authority to enter | Short form |
|---|---|---|
| Driver's license or state ID | The state or territory that issued it | Texas, TX, Texas DPS |
| Social Security card | Social Security Administration | SSA |
| U.S. passport or passport card | U.S. Department of State | DOS |
| Birth certificate | The state, county, or city vital records office that issued the certified copy | State of Ohio, Cook County |
| Permanent Resident Card (green card) | U.S. Citizenship and Immigration Services | USCIS |
| Employment Authorization Document (EAD) | U.S. Citizenship and Immigration Services | USCIS |
| Foreign passport | The country that issued the passport | Mexico, India |
| Form I-94 | U.S. Customs and Border Protection, or USCIS when USCIS issued it | CBP or USCIS |
Issuing authority means whoever has the legal power to create the document, keep the record behind it, and cancel or replace it. On a driver's license that's the state, which is why the state name runs across the top of the card. On a Social Security card it's SSA, no matter which state the employee lived in when the card was mailed.
The term shows up on plenty of forms besides the I-9. Banks, background-check vendors, and government applications ask for the "issuing authority of a valid photo ID" and mean the same thing. For a driver's license or state ID, enter the state; for a passport, the country (or the U.S. Department of State for a U.S. passport).
List A documents prove identity and work authorization on their own. Several of them are really two or three documents presented together, and each piece gets its own entry. The form gives you three sets of List A fields for this, and the Form I-9 instructions say to use the Additional Information box for anything beyond that.
| List A document | Issuing authority for each piece |
|---|---|
| U.S. passport or U.S. passport card | U.S. Department of State (DOS). Field-by-field guide: passport issuing authority. |
| Permanent Resident Card (Form I-551) | USCIS. Older cards may show DHS, or INS on the peach-colored Resident Alien cards that never expire. |
| Employment Authorization Document (Form I-766) | USCIS. Same entry for an auto-extended EAD presented with its Form I-797C. |
| Foreign passport with temporary I-551 stamp or MRIV | Line 1, the passport: the issuing country. Line 2, the I-551 stamp: the U.S. agency shown on the stamp (DHS or USCIS). For a machine-readable immigrant visa (MRIV), the U.S. Department of State, which issues the visa. |
| Foreign passport with Form I-94 (work-authorized nonimmigrant, such as H-1B) | Line 1, the passport: the issuing country. Line 2, the I-94: CBP, or USCIS when USCIS issued it with an extension or change of status. |
| F-1 student (CPT): passport, I-94, and Form I-20 | Passport: the country. I-94: CBP or USCIS. I-20: the school whose designated school official endorsed it. |
| J-1 exchange visitor: passport, I-94, and Form DS-2019 | Passport: the country. I-94: CBP or USCIS. DS-2019: U.S. Department of State, as M-274 Section 13.1 describes it. |
| FSM or RMI passport with Form I-94 | Passport: Federated States of Micronesia or Republic of the Marshall Islands. I-94: CBP. |
The combination rows are easy to get half right. An H-1B hire hands over a passport and a printed I-94, HR records the passport, and the second line stays empty. ICE reads that as a List A document that was only half recorded. M-274 Section 13.1 says CBP and USCIS both issue Form I-94; the printout from the CBP website is a CBP record, and an I-94 attached to a USCIS approval notice came from USCIS.
An employee who uses List B also shows a List C document. For most List B documents the issuing authority is printed on the front, and the state name alone is enough on a license.
| List B document | Issuing authority to enter |
|---|---|
| Driver's license or ID card from a state or U.S. territory | The state or territory (Texas, California, Puerto Rico, Guam) |
| Federal, state, or local government ID card | The agency or government that issued it (U.S. Department of Defense for a CAC, City of Houston for a city employee ID) |
| School ID card with photo | The school or university |
| Voter registration card | The state or county election office named on the card |
| U.S. military card or military dependent's ID card | U.S. Department of Defense (DOD) |
| U.S. Coast Guard Merchant Mariner Card | U.S. Coast Guard (USCG) |
| Native American tribal document | The tribe (Navajo Nation, Cherokee Nation) |
| Canadian driver's license | The province or territory (Ontario, British Columbia) |
| School record, report card, or clinic, doctor, hospital, day-care, or nursery school record (under 18 only) | The school, clinic, or facility that issued the record |
Minors who have no List B document at all are handled differently. A parent or guardian completes Section 1 and the Supplement A preparer block, and you write "Individual under age 18" in the List B column, per M-274 Section 4.2. There's no issuing authority for that entry. The same goes for "Special Placement" for workers with disabilities placed through a rehabilitation program.
| List C document | Issuing authority to enter |
|---|---|
| Social Security card without restrictions | Social Security Administration (SSA) |
| U.S. birth certificate with an official seal | The state, county, city, or territory office that issued it |
| Certification of report of birth (Form FS-545, DS-1350, or FS-240) | U.S. Department of State (DOS) |
| Native American tribal document | The tribe |
| U.S. Citizen ID Card (Form I-197) or Resident Citizen ID Card (Form I-179) | INS, the agency that issued these cards before USCIS existed |
| Employment authorization document issued by DHS (List C #7) | The DHS agency on the document. CBP or USCIS for an I-94 issued to an asylee; USCIS for a Refugee Travel Document (I-571), Reentry Permit (I-327), Certificate of Citizenship (N-560), or Certificate of Naturalization (N-550). Older certificates may say INS. |
List C is where the Social Security card questions come from. Write SSA even when the employee says the card "came from" their state; SSA is the only agency that issues it. The card also can't be laminated or carry a restriction such as "VALID FOR WORK ONLY WITH DHS AUTHORIZATION," per M-274 Section 13.3, and no issuing authority entry fixes a card that isn't acceptable to begin with.
Birth certificates need the office that issued the certified copy, which is the agency named in the seal. A hospital keepsake certificate with the baby's footprints isn't issued by a state, county, or city, so it doesn't qualify. Puerto Rico birth certificates count only when issued on or after July 1, 2010.
A receipt for a lost, stolen, or damaged document takes the issuing authority of the agency handling the replacement, which is the same agency that issues the document. M-274 Appendix A suggests titles like "Receipt: Replacement VA DL," so the issuing authority for that line is Virginia. When the replacement arrives within 90 days, record its title, issuing authority, number, and expiration in Additional Information, then initial and date the note.
An EAD that's been automatically extended still lists USCIS as the issuing authority. Record the extended expiration date and note the Form I-797C or Federal Register notice that extended it in Additional Information; our EAD auto-extension guide covers which renewals still qualify after October 30, 2025.
Supplement B has no issuing authority field at all, so for reverification you enter the document title, number, and expiration date only, which matches the Supplement B entries USCIS lists on its self-audit page.
A missing issuing authority is a substantive violation, and paperwork fines run $288 to $2,861 per form. Paper forms filled out at a jobsite and records imported from another system are the first places to look, since the field is easy to skip or map wrong. Our I-9 audit team reviews every Section 2 entry, tells you which forms need a correction note, and shows you how to make it without creating a bigger problem.
"DMV" with no state is a weak entry. Every state has one, so a reviewer can't tell which license was examined. Add the state, or write the state alone. Another one to catch is the employee's country of citizenship written as the issuing authority for a green card or EAD. Those cards come from USCIS, whatever the employee's nationality.
"SSA," "DOS," "USCIS," and state postal codes are fine as abbreviations. A shorthand only your office uses isn't, since USCIS says on its self-audit page that abbreviations must be widely understood.
Fixing a blank or wrong entry is simple when you know what the employee showed you. Draw a line through the wrong information, enter the correct issuing authority, and initial and date the change, following the USCIS correction steps. Never backdate it, and don't guess at a document you no longer have a record of. Our guide on how to fix I-9 mistakes walks through the cases where a note to file is the better move.
It's the government office that issued the document the employee presented. You record it in Section 2 with the document title, document number, and expiration date. For a driver's license that's the state; for a Social Security card, SSA; for a U.S. passport, the U.S. Department of State.
It's the Social Security Administration, so write "Social Security Administration" or "SSA." Only unrestricted, unlaminated cards are acceptable for List C.
The vital records office that issued the certified copy, which is usually a state health department, a county, or a city. Look at the seal and enter that state, county, or city, for example "State of Florida" or "Harris County."
Enter the state or territory that issued it. "Texas" or "TX" is enough, and you don't need "Department of Public Safety" or "DMV." For a Canadian license, enter the province.
The U.S. Department of State, for both the passport book and the passport card. Write "U.S. Department of State" or "DOS." Our passport guide covers the document number and expiration fields.
Both come from USCIS. Older green cards may show INS or DHS, and either entry matches the card, but never the employee's home country.
It's the agency named on the ID. That's the state for a driver's license or state ID, the U.S. Department of State for a U.S. passport, and the issuing country for a foreign passport.
Yes. M-274 Section 4.0 allows common abbreviations for states, document titles, and issuing authorities, such as "SSA" for the Social Security Administration, as long as a stranger reading the form would recognize them.
No. Reverification and rehire entries in Supplement B record the document title, document number, and expiration date.
Our compliance team answers I-9 questions every day, including the odd documents that aren't in any table. Reach us here: