
You are in Section 2 with a new hire's U.S. passport open on the counter. The data page shows a place of birth, maybe Houston, and a long passport number under a barcode. The form asks for issuing authority, and the city on the page is not it.
For Form I-9, the issuing authority on a U.S. passport is the United States Department of State. That is what most passport data pages name in the header. USCIS also accepts USA, United States, U.S. Department of State, or DOS under the M-274, Section 4.0 abbreviation rule. Do not copy the city, the National Passport Center, or anything from the passport number field.
The issuing authority is the government that created and stands behind the document. On a U.S. passport book or U.S. Passport Card, that is the U.S. Department of State. Both are List A document #1 on the M-274 List A. An employee who presents either one alone does not need List B or List C.
HR teams ask what exact string to type. For most U.S. passport books and passport cards, use the agency name from the data page header:
These do not:
The passport data page is easy to misread because several labels sit close together. The passport number is the unique identifier for that booklet or card. The expiration date is its own field on Section 2. The issuing authority is not a line item on the data page the way the number is. It is the government named in the header: United States of America, Department of State.
A passport book and a passport card use the same issuing authority rule. The card has a different document number format (one letter plus eight digits). Record each document exactly as presented.
| Section 2 field | U.S. passport book | Example |
|---|---|---|
| Document title | U.S. Passport or Passport | U.S. Passport |
| Issuing authority | United States Department of State (USA or United States also accepted) | United States Department of State |
| Document number | Passport number on the data page (9 characters) | 123456789 |
| Expiration date | Expiration date on the data page | 03/15/2031 |
If you use E-Verify, a U.S. passport still satisfies the photo requirement when it is the List A document. That is an E-Verify rule, not a change to what goes in the issuing authority column.
A U.S. passport alone completes Section 2 as List A. A foreign passport alone does not, unless it is one of the List A combinations (temporary I-551 stamp, Form I-94 with work authorization, FSM/RMI passport with I-94). For those combos, the foreign passport's issuing authority is the country that issued it (Canada, India, Mexico), not the United States. Full walkthrough: what is work authorization and the I-9 documents list.
The place-of-birth city is the mistake we see most. Houston prints on the same spread as the photo, so someone types Houston in issuing authority and moves on. That city tells you where the employee was born. It does not tell you who issued the passport.
Passport number confusion runs a close second. The nine-character number under the barcode is the document number field. Putting it in issuing authority leaves Section 2 with no valid identifier for the passport itself. If ICE pulls the I-9 later, the record will not match what was on the counter.
Over-documentation is the third pattern. A valid U.S. passport is List A. When the employee puts it on the table, you are done. Asking for a driver's license "to be safe" creates an over-documented file and can raise discrimination questions under INA section 274B.
An expired passport is the fourth. Correct issuing authority does not rescue an expired document. The passport must be unexpired on the date you complete Section 2. Wrong document recording on Section 2 can fall in the paperwork penalty range of $288–$2,861 per form (January 2, 2025 Federal Register). Full table: 2026 I-9 penalties.
"On a U.S. passport we tell clients to type United States Department of State in Section 2," says Patricia Duarte, Director of Compliance at i9 Intelligence. "That is what the data page names. We still see Houston, Dallas, or National Passport Center in that field because something else is printed nearby. That is not the issuing authority."
Passports are only one Section 2 field. Driver's licenses use the state name. Social Security cards use SSA. Green cards and EADs use USCIS. Birth certificates use the state or county that recorded the birth. Full tables for every List A, B, and C document: issuing authority on Form I-9. On the current form edition: Form I-9 2026 guide.
Not sure what your team has been typing? Book a free compliance call and we will spot-check a sample of your Section 2 entries against the documents they were supposed to match.
The United States Department of State. That is the agency named on most U.S. passport data pages. USA, United States, U.S. Department of State, or DOS also work. Do not enter the employee's name or the city shown on the passport data page.
Same as a passport book: United States Department of State. The U.S. Passport Card is List A document #1. Record its own document number (one letter plus eight digits) in the number field.
No. The issuing authority is the government that issued the document. The passport number goes in the Document Number column on Section 2.
Those are processing or birth-location labels, not the issuing authority for I-9. Use United States Department of State.
No. The passport must be unexpired when you examine it for Section 2. A correct issuing authority entry does not fix an expired List A document.
If you are staring at a U.S. passport and the issuing authority field is blank, the answer is United States Department of State, not the city on the data page. Call before someone edits a completed I-9 to match a software dropdown.
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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