7 Remote I-9 Verification Mistakes to Avoid in 2025

Top 7 Remote I-9 Verification Mistakes (and How to Avoid Them in 2025)

Remote work isn’t going anywhere—and neither are your I-9 compliance obligations. Since DHS made permanent the option for certain employers to complete Form I-9 remotely, HR teams have had to adapt fast.

But here’s the problem: remote I-9 verification has its own set of pitfalls, and a single oversight can trigger an ICE audit, fines, or even accusations of discrimination.

This article outlines the seven most common mistakes employers make with remote I-9 verification, why they happen, and — most importantly — how to avoid them.

1. Not Knowing If You Qualify for Remote Verification

One of the biggest misconceptions is that all employers can use remote verification. In reality, only enrolled E-Verify employers in good standing are eligible under the DHS final rule (effective August 1, 2023).

Avoid It:

• Confirm your E-Verify status and compliance history.
• Keep enrollment and status documentation on file.

Related: What States Require E-Verify

2. Failing to Use Live Video Technology

Some employers still try to verify documents via email or texted photos alone. DHS guidance requires live, real-time interaction (video conferencing) so the HR rep can compare the person to the documents.

Avoid It:

• Use secure, recorded video platforms when conducting remote verification.
• Train staff to perform live, side-by-side comparisons of IDs and faces.

3. Inconsistent Document Review Standards

When different managers verify documents without clear guidelines, results vary — a red flag in audits.

Avoid It:

• Standardise verification steps across all hiring managers.
• Use checklists and sample images of acceptable documents.
• Regularly calibrate reviewers with refresher training.

4. Not Retaining Required Copies of Documents

Under the DHS remote verification rule, you must retain a clear copy of the documents presented for as long as the Form I-9 itself is retained. Missing or poor-quality images are a compliance violation.

Avoid It:

• Capture high-resolution images during the live video session.
• Store copies securely, with restricted HR-only access.

5. Forgetting to Update the I-9 Form with the Remote Verification Annotation

If you complete the I-9 remotely, DHS requires specific notations in the Additional Information field to show the alternative procedure was used.

Avoid It:

• Always add “Alternative Procedure Authorized by DHS” and the date of the live video review in Section 2.
• Audit forms monthly to catch missing annotations.

6. Skipping Reverification for Expiring Work Authorization

Remote I-9 doesn’t exempt you from reverification. Employers who forget to follow up risk employing someone without valid authorization.

Avoid It:

• Set automated reminders for reverification dates.
• Train managers to trigger re-verification workflows early.

7. Ignoring State-Specific Rules

Some states impose stricter requirements on top of federal rules — particularly for E-Verify use and public contractors. Remote I-9 doesn’t override these laws.

Avoid It:

• Maintain a current compliance map of all states you operate in.

Related: E-Verify State Requirements

Make Remote I-9 Compliance a Strength, Not a Liability

Remote I-9 verification can be a huge time-saver and a competitive hiring advantage—but only if it’s done right. By avoiding these seven mistakes, employers can protect themselves from costly fines, strengthen their compliance posture, and give their HR teams confidence in every hire.

Want to speak to an I-9 compliance expert? Book a Free Compliance Review and we’ll analyse your remote I-9 process for gaps before they become audit risks.

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