What Is an Unrestricted Social Security Card? Employer Rules for Form I-9
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The reverification email lands at 7:41 AM on a Monday. An EAD expires Wednesday. The first instinct is to grab a blank Form I-9 and start over. Don't. Reverification and most rehires go on Supplement B, the second page of the current Form I-9, and stay attached to the employee's original I-9. Creating a new form when you should have used Supplement B is one of the errors ICE now treats as substantive in the March 2026 Inspection Fact Sheet, which means the fine attaches per form.
This guide is the field manual for that second page. When Supplement B applies, when it doesn't, what to write in each field, which errors ICE reclassified in March, and how the remote alternative procedure works when the reverification lands on someone who was never in your office to begin with. Every rule below is from M-274 §6 and the March 2026 ICE fact sheet.
Supplement B replaced the old Section 3 when USCIS split the form in August 2023. Same purpose: reverification and rehire. Different location. On its own page instead of the bottom of the original form. Use one block of Supplement B for one event (a reverification, a rehire, a name-only update). If the employee needs another update later, use the next block down. If all four blocks are used, attach a fresh Supplement B page and keep both with the original I-9.
Three questions decide whether Supplement B is the right instrument:
| Situation | Instrument | Why |
|---|---|---|
| Current employee's work authorization document is about to expire | Supplement B (one block, reverification) | M-274 §6.1. Same employer, same job, continuous employment. |
| Rehire within 3 years of original I-9 completion | Supplement B (one block, rehire) | M-274 §6.2. New I-9 is optional but not required. |
| Legal name change on a current employee | Supplement B (name-only block) | M-274 §6.3. Enter only the fields that changed. |
| Rehire more than 3 years after the original I-9 | New Form I-9 | M-274 §6.2. Old form is out of scope; start over with a new hire. |
| Previous reverification is on an obsolete form version | Supplement B on the current form, attached to the original | M-274 §6.1. Never modify the old page; attach the new one. |
| Employee reveals they were working under a false identity | New Form I-9, attached to the original with a written explanation | M-274 §6.3. Enter the original hire date in Section 2 of the new form. |
Two things Supplement B is never for. It is never for U.S. citizens or noncitizen nationals, because those employees are never reverified. And it is never for reverifying a List B document that expired. List B proves identity; identity does not expire for I-9 purposes even when the driver's license does. Only List A or List C documents with a real work-authorization expiration trigger Supplement B, and even then only for employees whose Section 1 attestation included an expiration date (aliens authorized to work, not LPRs who marked their status).
M-274 §6.1 gives one deadline and one substantive rule. The deadline: on or before the date the employee's work authorization expires. Not the day after. Not "when we get to it." A reverification completed one day late is a substantive Section 2/Supplement B violation. The rule: the employee chooses the document from List A or List C. You do not tell them what to bring. Doing so is document abuse under 8 U.S.C. §1324b.
Reverification is triggered by Section 1, not by the documents. The employee's original attestation created the trigger: they marked "alien authorized to work" and entered an expiration date. On or before that date, you reverify. If Section 1 shows "N/A" in the expiration field (asylees, refugees, certain COFA citizens), there is no reverification unless the employee originally chose to present a document that itself expires (typically an EAD). Then reverify by the document's expiration, not by status.
What the employee presents is their choice from List A or List C, including an unrestricted Social Security card. Present a restricted Social Security card (VALID FOR WORK ONLY WITH DHS AUTHORIZATION, VALID FOR WORK ONLY WITH INS AUTHORIZATION, or NOT VALID FOR EMPLOYMENT)? Reject it and ask them to pick a different List A or C document. Full breakdown: "Valid for Work Only with DHS Authorization" on the I-9.
One reverification event fills one Supplement B block. Fill the fields in this order:
| Field | What to enter |
|---|---|
| Employee's full name (top of page) | The name from the original Form I-9. Not the new name. |
| New Name fields | Only if the name has changed since the original. Enter only the parts that changed. Last name only? Fill just the Last Name field. |
| Date of Rehire | Leave blank for a straight reverification. This field is for rehires only. |
| Document Title | The exact title (e.g., Employment Authorization Document, not "EAD"; Social Security Account Number Card, not "SSN card"). Match the M-274 wording. |
| Document Number | The number printed on the document. For an EAD it's the card number in the top-right. Not the A-Number. |
| Expiration Date | The date printed on the new document, or the operative extension date if the employee is relying on a USCIS auto-extension notice (see the EAD auto-extension guide for current cutoff rules). |
| Employer signature, printed name, and date | Signed on or before the previous authorization expired. This is where missed reverifications become paperwork violations. |
Keep the supplement page physically or electronically attached to the original I-9. Never separate them.
Rehire an employee within three years of the date you completed their original Form I-9 and you have a choice: complete a fresh block on Supplement B, or start a new Form I-9 from scratch. M-274 §6.2. Most employers use Supplement B because it's faster and preserves the original record. The choice splits based on whether the employee's authorization is still valid.
This is the light-touch version. U.S. citizens, noncitizen nationals, and lawful permanent residents who originally presented a Form I-551 fall here almost by default, because their authorization doesn't expire. Aliens whose Section 1 attestation still hasn't reached its expiration date also fall here. Fill in:
You do not ask them to present documents again. Their existing authorization carries. Skipping the documents in this scenario is not a violation; requiring them anyway is document abuse.
Rehire and reverification collapse into one block. Fill in everything from the light-touch version, and then also fill in the reverification fields (document title, number, expiration date) from a currently valid List A or List C document the employee chose. Sign and date on or before the day they start work.
Three cases force a new form. First, the previous I-9 is on an obsolete version. Second, the original I-9's Supplement B is full (all four blocks used), and rather than attach another supplement page you elect to start clean. Third, and this one is mandatory: the employee is being rehired more than three years after the original I-9 date. That's a new-hire event, no discretion.
Reverification is the single biggest source of quiet paperwork violations we find in audits. A blocked calendar reminder that never fired, a Supplement B started but not signed, a rehire treated as a new I-9 when the original was 30 months old. Our compliance team will pull your active roster, flag every reverification that's due in the next 60 days, and walk you through the fix. Schedule a free compliance call.
An employee gets married and changes their last name. No reverification, no rehire. Just a name change. Use one block of Supplement B and fill in only two things:
Leave the document title, number, and expiration date empty. Leave the rehire date empty. USCIS recommends you ask for legal documentation of the name change (marriage certificate, court order) and keep a copy attached to the I-9. If your employee is in E-Verify, they should also update their name with SSA to avoid future TNC mismatches. Don't create a new E-Verify case just because a name changed.
Identity change is a different animal. If an employee reveals they were working under a false identity and now presents documents in their true identity, you do not use Supplement B. Complete a new Form I-9, write the original hire date in Section 2, attach the new form to the previously completed I-9, and include a written explanation. INA anti-discrimination provisions apply, and I-9 rules do not require termination in this scenario.
The March 2026 ICE I-9 Inspection Fact Sheet reclassified a group of Supplement B errors from technical (fixable in the 10 business days ICE gives you after a Notice of Inspection) to substantive (fine attaches per form, current range $288–$2,861 under the January 2025 penalty adjustment). Know the specific errors that got moved:
| Supplement B error | Pre-March 2026 | March 2026 onward |
|---|---|---|
| Missing rehire date | Technical (2009 ICE memo) | Substantive |
| Failure to date Supplement B by the authorization expiration date and verify the new documents | Technical | Substantive |
| Missing document title, number, or expiration date on Supplement B | Technical | Substantive |
| Missing employer printed name or signature on Supplement B | Technical | Substantive |
| Failure to verify a replacement document within the 90-day receipt window | Technical | Substantive |
| Missing employee full name at top of Supplement B | Technical | Technical (still fixable within 10 business days) |
| Missing new name (when a name change occurred) | Technical | Technical (still fixable within 10 business days) |
Two of the reclassified errors deserve a specific note. The first is missing rehire date, which used to be a checklist gap and is now a per-form fine. The second is the signature and date must be on or before the previous authorization expired. A Supplement B block that's complete and signed on the correct day is fine. The same block signed one day late is a substantive violation. Full context on which errors moved: Form I-9 Section 2: The Mistakes ICE Now Treats as Substantive.
Reverifications land on the same remote employees you hired remotely in the first place, often more frequently, because EADs and TPS-based authorization tend to renew on 1- or 2-year cycles. Two workflows apply.
DHS alternative procedure (E-Verify-enrolled employers in good standing). The employee sends clear photos or scans of the new List A or List C document in advance. You inspect them, then conduct a live video call to compare the physical document to the images and to the person. Retain a copy of both sides of the document with the Supplement B record. Check the "Alternative Procedure" box on the supplement. Same rules as new-hire alternative procedure: only E-Verify employers, only in good standing, and only for employees whose original Section 2 was also completed under the alternative procedure or who are being newly reverified.
Authorized representative. Someone you designate (an HR partner, an i9 Intelligence remote-verification specialist, or in a pinch a trusted third party) physically inspects the new document with the employee and completes Supplement B on your behalf. The representative signs. Employer liability stays with you, so pick someone trained. The M-274 no-notary myth still applies: notaries can serve as authorized representatives; they are not notarizing the I-9.
Receipts work at reverification too. If the employee's replacement List A or List C document was lost, stolen, or damaged, they may present a receipt for the replacement and have 90 days to produce the actual document. Record the receipt in the block, then update the block with the real document number and expiration date when it arrives. Failing to close the receipt loop within 90 days is now a substantive violation.
Five of these come up in almost every audit we run. Do not create a new Form I-9 for a straight reverification when the original I-9 still has open Supplement B blocks; you generate duplicate records that ICE reads as inconsistent recordkeeping. Do not tell the employee which document to bring; the employee chooses. Do not reverify a List B document; identity doesn't expire. Do not open an E-Verify case at reverification; E-Verify is a new-hire tool and running the case again looks like a fresh hire event you can't explain. Do not backdate the employer signature on Supplement B; the signature date is the audit-anchor, and moving it after the fact is worse than a late reverification you own honestly.
"The Supplement B block that gets us in trouble is almost always the one an HR generalist started on Monday, meant to finish Tuesday, and signed the following week. It looks like the paperwork got done. ICE sees a substantive violation per form because the signature landed after the authorization expired. Our rule with clients: if you can't finish and sign Supplement B on the day of the reverification meeting, don't start it that day. Block time for the signature first," says Patricia Duarte, Director of Compliance at i9 Intelligence.
Supplement B is where the reverification calendar becomes real paperwork. If you're staring at a list of EAD expirations in the next 60 days, or you inherited a stack of I-9s and need someone to tell you which ones are missing a signature, we do this every day.
Phone: (713) 668-6200 (Monday to Friday, 8 AM to 5 PM CT)
Email: support@i-9intelligence.com
Ticket: Submit a ticket
Supplement B is the second page of the current Form I-9 (August 2023 revision and forward). It replaced the old Section 3, and it handles two events: reverifying an employee whose work authorization is about to expire, and rehiring an employee within three years of their original I-9. Each event uses one block. Four blocks fit on one supplement page; use additional pages if needed.
On or before the date the employee's current work authorization expires. Signed and dated by the employer on the day the reverification meeting happens, not later. A Supplement B block signed one day after the expiration is now a substantive violation under the March 2026 ICE fact sheet.
If the rehire is within three years of the original I-9 date, yes: use one block of Supplement B and enter the rehire date. If the rehire is more than three years after the original I-9, complete a new Form I-9. The three-year window runs from the date the original I-9 was completed, not from the last day of employment.
No. Reverification is triggered by an expiring work-authorization document that the employee originally chose to present, or by an expiration date in Section 1. Becoming an LPR is a status upgrade, not a document expiration. If they want their I-9 updated to reflect their new status, complete a new Form I-9 rather than Supplement B, because Section 1 needs to change. Do not open an E-Verify case for the update.
Yes, two ways. If you're enrolled in E-Verify in good standing, the DHS alternative procedure applies to reverifications the same way it applies to new hires: live video inspection after receiving clear document images. If you're not on the alternative procedure, an authorized representative can inspect the physical document with the employee and complete Supplement B on your behalf. Employer liability stays with you either way, so pick the representative carefully.