TPS Status for Employers: I-9 and E-Verify Instructions by Country (October 2026)

Special Work Status
1
minutes to read
U.S. Supreme Court pediment illuminated at night with Equal Justice Under Law inscription

Updated October 19, 2026. Sudan and Ukraine extension notices ran through October 19, 2026, and as of that date DHS hadn't published a termination notice or a new date for either country, so check the Sudan and Ukraine country pages before you reverify anyone. Until USCIS posts a new date, enter April 19, 2027 as a placeholder, the same way as El Salvador. Venezuela 2023 documents stopped being valid after October 2. El Salvador work authorization still continues under the USCIS country-page alert.

Temporary Protected Status (TPS) lets nationals of designated countries live and work in the United States when conditions at home make it unsafe to return. Every designation on USCIS's radar is in transition following the U.S. Supreme Court's June 25, 2026 ruling in Mullin v. Doe. Match the employee's country to the Quick Reference table below for the operative date and the I-9 move. A12 and C19 EADs from a terminated designation are no longer valid; reverify those workers on Supplement B.

The Post-Mullin Reverification Workflow

All seven terminated post-Mullin designations run the same workflow. For any employee whose Section 2 recorded an A12 or C19 EAD tied to Yemen, Haiti, Syria, Burma, South Sudan, Somalia, or Ethiopia, complete Supplement B of the existing I-9 with a currently valid List A or List C document the employee chooses. If the employee cannot produce one, employment cannot continue. Termination-effective dates, Federal Register cites, and superseded court cases for each of the seven are in the Quick Reference table below. El Salvador is not in that queue. The El Salvador workflow is in the country row and in the section immediately after the table. For workforce-planning context on the post-Mullin cascade, see After Mullin v. Doe: The HR Playbook for Every TPS Termination.

Quick Reference: TPS Status by Country

Every TPS designation currently on USCIS's radar, with the operative Form I-9 date, the Federal Register basis, and the governing court case (where applicable). This table is the single source of truth for the rest of this guide.

Country Status Operative Date / Expiration Federal Register / Court
Somalia Terminated post-Mullin; A12/C19 EADs no longer valid; reverify on Supplement B Aug. 14, 2026 91 Fed. Reg. 1547 (Jan. 14, 2026); Mullin v. Doe, 609 U.S. __ (2026); African Communities Together v. Noem, 26-cv-11201 (D. Mass.) superseded
Ethiopia Terminated post-Mullin; A12/C19 EADs no longer valid; reverify on Supplement B Aug. 18, 2026 90 Fed. Reg. 5802; Mullin v. Doe; African Communities Together v. Noem, 26-cv-10278-BEM (D. Mass.) superseded
Yemen Terminated post-Mullin; A12/C19 EADs no longer valid; reverify on Supplement B July 20, 2026 91 Fed. Reg. 10402; Mullin v. Doe
Haiti Terminated post-Mullin; A12/C19 EADs no longer valid; reverify on Supplement B July 27, 2026 90 Fed. Reg. 54733; Mullin v. Doe
Syria Terminated post-Mullin; A12/C19 EADs no longer valid; reverify on Supplement B July 27, 2026 90 Fed. Reg. 45398; Mullin v. Doe
Burma Terminated post-Mullin; A12/C19 EADs no longer valid; reverify on Supplement B Aug. 7, 2026 90 Fed. Reg. 53378; Aung DOE v. Noem, 25-cv-15483 (N.D. Ill.) superseded
South Sudan Terminated post-Mullin; A12/C19 EADs no longer valid; reverify on Supplement B Aug. 7, 2026 90 Fed. Reg. 50484; African Communities Together v. Noem, 25-cv-13939-PBS (D. Mass.) superseded
El Salvador Pending further announcement; ~170,000 beneficiaries. USCIS country-page alert: Salvadoran individuals present in the U.S. under TPS retain protection including work authorization until DHS announces otherwise. No new auto-extension date. No new termination date. Do not treat Sept. 9, 2026 as a lapse. Do not reverify off solely because that date passed. Expired A12/C19 EAD plus the country-page alert is the current I-9 posture; see the El Salvador section below. Pending. Country-page table still lists Sept. 9, 2026 as the prior continuation date. That date is not the current instruction. USCIS El Salvador TPS country-page alert (current as of Sept. 21, 2026); 90 FR 5953 (January 17, 2025). The Sept. 3, 2026 I-9 Central news item still shows the older "set to terminate Sept. 9" language and has not been updated to match the country-page alert.
Sudan Check the country page. Qualifying A-12/C-19 EADs (April 19, 2025 and eight earlier expiration dates, or any date from July 22, 2026 through Oct. 18, 2026) paired with the USCIS extension notice were valid through Oct. 19, 2026. The Sept. 3, 2026 E-Verify notice says the designation is "set to terminate" Oct. 19, but as of that date no Federal Register termination had been published. See the Sudan and Ukraine section below before acting. Oct. 19, 2026 (check the country page for anything later) 90 FR 5944 (Jan. 17, 2025); VAM v. USCIS, Aug. 5, 2026 (D. Mass.); E-Verify Sudan update, Sept. 3, 2026
Ukraine Check the country page. ~101,000 beneficiaries. Qualifying A-12/C-19 EADs (April 19, 2025 or Oct. 19, 2023, or any date from April 20, 2026 through Oct. 18, 2026) paired with the USCIS extension notice were valid through Oct. 19, 2026. The Sept. 3, 2026 E-Verify notice says the designation is "set to terminate" Oct. 19, but as of that date no Federal Register termination had been published. See the Sudan and Ukraine section below before acting. Oct. 19, 2026 (check the country page for anything later) 90 FR 5936 (Jan. 17, 2025); VAM v. USCIS, Aug. 5, 2026 (D. Mass.); E-Verify Ukraine update, Sept. 3, 2026
Lebanon Active; extended 6 months in May 2026 Nov. 27, 2026 89 FR 93641 (Nov. 27, 2024) + May 2026 auto-extension
Venezuela 2023 Documents expired Oct. 2, 2026; the termination took effect in 2025, and a district court order kept qualifying EADs, I-797s, and I-94s valid only through Oct. 2, 2026. USCIS has published no later date. Reverify on Supplement B. Oct. 2, 2026 90 FR 9040; Supreme Court stay Oct. 3, 2025; N.D. Cal. order May 30, 2025; USCIS Venezuela page
Afghanistan Terminated 2025; A12/C19 EADs no longer valid July 22, 2025 Fourth Circuit denied stay July 21, 2025
Cameroon Terminated 2025; A12/C19 EADs no longer valid Aug. 4, 2025 June 4, 2025 FR notice
Nepal Terminated 2025; A12/C19 EADs no longer valid Aug. 20, 2025 June 6, 2025 FR notice; Ninth Cir. stay Feb. 9, 2026
Honduras Terminated 2025; A12/C19 EADs no longer valid Sept. 8, 2025 July 8, 2025 FR notice; Ninth Cir. stay Feb. 9, 2026
Nicaragua Terminated 2025; A12/C19 EADs no longer valid Sept. 8, 2025 July 8, 2025 FR notice; Ninth Cir. stay Feb. 9, 2026
Venezuela 2021 Terminated 2025; A12/C19 EADs no longer valid Nov. 7, 2025 Sept. 8, 2025 FR notice; Supreme Court stay Oct. 3, 2025

* See the expiration playbook below for the VAM ruling and how the one-year cap affects Sudan and Ukraine EADs.

What to Do When an Active TPS Designation Approaches Expiration

Sudan and Ukraine reached their October 19, 2026 date, Lebanon follows on November 27, 2026, and Venezuela 2023 documents stopped being valid after October 2. The playbook below is the one Ethiopia, Somalia, and the other post-Mullin countries ran through their termination-effective dates. El Salvador stopped partway, and Sudan and Ukraine may do the same, so read the next section before you act on either one.

Sudan and Ukraine: check the country page before you reverify

A Sudan or Ukraine A12 or C19 EAD paired with the USCIS extension notice was good through October 19, 2026. On September 3, E-Verify posted that both designations "are set to terminate on Oct. 19, 2026." As of October 19, DHS hadn't published a Federal Register termination for either country, and neither USCIS country page carried a new alert (both were last updated September 3). El Salvador was in the same spot on September 9, and USCIS answered with an alert saying work authorization continues rather than a termination.

Check the Sudan and Ukraine country pages and the E-Verify What's New page before you start Supplement B for anyone. Don't reverify a covered Sudanese or Ukrainian employee off, or end their employment, on the strength of the September 3 "set to terminate" line alone, because doing it before DHS publishes an actual end date creates the same 8 U.S.C. § 1324b exposure as El Salvador. Save a dated copy of each country page with the I-9 so the record shows what you relied on, and follow whatever date or document instruction USCIS posts next.

How to complete the I-9 until USCIS posts a new date. Patricia's instruction to customers on October 19, 2026 follows the El Salvador process. Accept the A12 or C19 EAD with the USCIS extension notice, enter April 19, 2027 in Section 1, Section 2, and E-Verify so the electronic form can save, add the Additional Information note below, and attach a dated copy of the country page. April 19, 2027 is six months past the last published date and works as a placeholder only, since USCIS hasn't published it, so overwrite it as soon as USCIS posts a real date.

El Salvador: work authorization continues, and USCIS has not published a new date

Do not treat September 9, 2026 as the end of El Salvador TPS work authorization. USCIS's El Salvador TPS country page currently states, verbatim:

"An announcement on El Salvador's TPS will be made at the appropriate time. Until such announcement is made, Salvadoran individuals present in the U.S. under TPS retain protection including work authorization."

That is not a Federal Register extension. It is not a new termination. It is not a new auto-extension date for A12 or C19 EADs. The country-page table still lists September 9, 2026 as the date TPS was previously continued through, and the September 3, 2026 I-9 Central news item still tells employers to enter September 9, 2026. The live alert at the top of the country page is the later instruction. Patricia Duarte, Director of Compliance at i9 Intelligence, is advising customers from that alert.

Do not reverify a covered Salvadoran TPS employee off solely because September 9 passed. Do not terminate a covered employee because "TPS ended." Either move is 8 U.S.C. § 1324b exposure. Watch the country page and I-9 Central for the next announcement, then follow whatever date or document combination USCIS publishes.

How to complete the I-9 while there is no new date. USCIS has not issued replacement Form I-9 or E-Verify instructions for this interim. The September 3 I-9 Central item still says to enter September 9, 2026. That date is now in the past, and electronic I-9 systems (including i9 Intelligence) will not accept an expired date in Section 1 or Section 2. Patricia's instruction to customers, September 18, 2026:

  • Accept the expired A12 or C19 EAD (and the USCIS extension notice, if the employee has one) as the List A document on file.
  • Enter a future date so the form can be completed. That date is a system placeholder. It is not a USCIS-published expiration.
  • Notate the Additional Information box with the USCIS alert.
  • Attach a dated copy of the El Salvador TPS country page to the I-9. The page will change when DHS announces the next step. The copy you save is the record of what you relied on.

Suggested Additional Information note: "El Salvador TPS: USCIS country-page alert states Salvadoran individuals present in the U.S. under TPS retain protection including work authorization until a further announcement. No new auto-extension or termination date published. Expired A12/C19 EAD accepted with this note. Country page attached."

When USCIS publishes a real expiration, extension, or termination date, overwrite the placeholder and follow that instruction. Until then, do not invent a six-, 12-, or 18-month end date and treat it as if DHS issued it.

The one-year EAD cap on Sudan and Ukraine EADs

Sudan and Ukraine EADs are subject to a one-year cap on the automatic 540-day extension. On August 5, 2026, the U.S. District Court for the District of Massachusetts in Venez. Ass'n of Mass. v. USCIS (VAM) upheld the DHS Cap Policy limiting TPS-based EADs to one year from July 22, 2025. The practical effect on the two still-active designations:

  • Sudan: EAD auto-extension ended April 19, 2026. The August 14, 2026 USCIS notice separately auto-extends qualifying A-12/C-19 EADs (April 19, 2025 and eight earlier expiration dates) through October 19, 2026 with USCIS extension notice.
  • Ukraine: Same 540-day cap. The August 14, 2026 USCIS notice separately auto-extends qualifying A-12/C-19 EADs (April 19, 2025 and October 19, 2023) through October 19, 2026 with USCIS extension notice. Check the specific dates on the USCIS Ukraine country page.

The same cap previously applied to El Salvador EADs. That population is now on the country-page alert, not on a published auto-extension date. USCIS confirmed on July 23, 2026 that previously issued TPS-based EADs retain their printed expiration dates. Outside a USCIS extension-notice window, the card is valid only until the date printed on it unless a later USCIS alert says otherwise. El Salvador is the current exception: the country-page alert continues work authorization with no new printed date.

T-60 to T-30 days: audit and pre-stage

  1. Pull every I-9 with an A(12) or C(19) EAD. Filter by category code, not country of birth. Country-of-birth audits create anti-discrimination exposure under 8 U.S.C. § 1324b enforced by IER.
  2. Cross-reference each record against the country's row in the Quick Reference table. For active-country EADs, check the card's printed expiration date directly. Ignore the auto-extension for Sudan and Ukraine unless USCIS publishes a fresh Federal Register notice reopening it. For El Salvador, follow the country-page alert section above. Do not treat a passed September 9 date as a lapse.
  3. Flag any employee whose card expires on or before the country's TPS expiration date. These are your near-term reverification candidates regardless of what DHS decides about the underlying designation.
  4. Draft the reverification communication now. Frame it as a referral to immigration counsel, not a termination warning. Employees may have H-1B, L-1, family-based, adjustment-of-status, asylum, or cancellation-of-removal pathways.

T-14 days: watch the Federal Register and E-Verify

DHS typically publishes an extension or termination notice 30 to 60 days before a TPS expiration. In 2026 it has also let dates arrive with no notice and posted a country-page alert afterward, which is what happened with El Salvador. Monitor:

  • The country's USCIS TPS page, which USCIS updates on a rolling Friday cadence.
  • The E-Verify What's New page, which publishes formal termination guidance whenever DHS issues one.
  • The Federal Register USCIS agency feed for the actual notice text.

Save timestamped screenshots of each daily check. If DHS terminates, the good-faith-reliance record is your audit defense.

T-0 (expiration day)

If DHS publishes an extension: Update the operative date across your I-9 population using the Federal Register cite. Note the new date in Section 2 and in the E-Verify case where applicable. No Supplement B required for a straight extension.

If DHS publishes a termination: Run the reverification workflow described below for terminated designations. A12 and C19 EADs from the terminated country are no longer valid as of the effective date, regardless of the printed expiration on the card.

If DHS publishes nothing and the date passes: Check the country page before you treat the designation as lapsed. With El Salvador, September 9, 2026 passed without a Federal Register extension or termination, and USCIS posted an alert that work authorization continues until a further announcement. Sudan and Ukraine reach the same point on October 19. Don't run the terminated-designation workflow until DHS publishes an end date, save a timestamped screenshot of the country page each day, and update the I-9 when USCIS posts the new date or document instruction.

Post-expiration: 60-day litigation window

Every 2025 TPS termination has been litigated. Expect the same for any 2026 termination. If a court issues a stay after a termination effective date, USCIS will publish a follow-up bulletin restoring work authorization for a limited period. Track the country's USCIS page daily until the litigation posture is clear. Do not re-hire an employee you already reverified off; wait for a specific stay-restoration bulletin.

"El Salvador does not have a new auto-extension date or a new termination date. USCIS's last notice says Salvadoran TPS holders retain protection, including work authorization, until an announcement is made. That is what I am telling customers. Put a future date on the I-9 so the form can be completed with the expired document, notate the alert in Additional Information, and attach the country page. Do not reverify someone off because September 9 came and went," says Patricia Duarte, Director of Compliance at i9 Intelligence.

Schedule a Free Compliance Call to audit your active-country TPS population before the next scheduled expiration.

Reverification Workflow for Terminated Designations

The steps below apply identically to the seven terminated post-Mullin countries (Yemen, Haiti, Syria, Burma, South Sudan, Somalia, Ethiopia). Termination-effective dates, Federal Register cites, and superseded court cases for each are in the Quick Reference table above. El Salvador is not in this workflow.

  • Section 1 (new hires): The employee must attest to current authorization based on a valid document category, not the terminated TPS.
  • Supplement B (existing employees): Required for any A12 or C19 EAD previously accepted from the terminated country. Record the new document's title, issuing authority, number, and expiration date. If the employee cannot produce a currently valid List A or List C document, employment cannot continue.
  • E-Verify: Do not open a new E-Verify case at reverification. E-Verify is a new-hire tool. Reverification lives on Supplement B of the existing Form I-9. E-Verify photo matching does not apply to Social Security cards; the photo-match tool covers only U.S. passport, U.S. passport card, Permanent Resident Card (I-551), and EAD (I-766).
  • Discrimination guardrails: During reverification, do not specify which document the employee must present. Employees choose from List A or List C. Do not demand original documents beyond what the form requires, and do not treat the reverification as a re-hire.
  • Previously issued EADs: All A12 and C19 EADs issued under a now-terminated TPS designation are invalid as of that designation's termination-effective date, regardless of the date printed on the card. If you are unsure whether an EAD was TPS-based, check the category code on the front of the Form I-766. A12 or C19 indicates a TPS-based EAD.

Handling These Countries on the I-9

New Hires

New hire from any of the seven terminated post-Mullin countries (Yemen, Haiti, Syria, Burma, South Sudan, Somalia, Ethiopia): Do not accept an A12 or C19 EAD tied to any of these designations. Their TPS is terminated and the underlying document is no longer valid List A evidence, regardless of the date printed on the card. The employee must present a different List A document or a List B + List C combination that establishes current work authorization. If they cannot, the new hire cannot proceed.

New hire with El Salvador TPS: Work authorization continues under the USCIS country-page alert. Accept a qualifying A12 or C19 EAD even if the printed date has passed. Enter a future date in Section 1, Section 2, and E-Verify so the electronic form can save, note the USCIS alert in Additional Information, and attach a dated copy of the country page. That future date is a placeholder, not a USCIS-published expiration. Do not refuse the hire because September 9, 2026 has passed.

New hire from Sudan, Ukraine, or Lebanon: Accept the A12 or C19 EAD as List A through its printed expiration date, or through the USCIS-extended date if a current extension notice applies. For Sudan and Ukraine EADs paired with the USCIS extension notice, check the country page on the day of hire. If USCIS still hasn't posted a date past October 19, 2026, enter April 19, 2027 as the placeholder in Section 1, Section 2, and E-Verify, add the Additional Information note, and attach the extension notice and a dated copy of the country page.

Don't accept a Venezuela 2023 TPS EAD from a new hire. The court-ordered validity for those documents ended October 2, 2026, so the employee needs a different List A document or a List B and List C combination.

Entering This in the i9 Intelligence Platform

The i9 Intelligence electronic I-9 platform will not accept free text in the Section 1 date field. It also will not accept an expired date. For Sudan and Ukraine A-12/C-19 EAD holders covered by the USCIS extension notice, enter April 19, 2027 in Section 1 as a placeholder until USCIS posts a date past October 19, 2026, and document the notice and country page in the Additional Information box in Section 2. For El Salvador, USCIS has not published a replacement date. Enter a future date so the form can save, and document the country-page alert in Additional Information. USCIS accepts Additional Information notations for electronic I-9 systems that cannot capture free-text dates.

Step-by-step in i9 Intelligence for Sudan, Ukraine, and El Salvador:

  1. Section 1 (Expiration Date): For Sudan and Ukraine, enter April 19, 2027 unless USCIS has posted a later date on the country page. For El Salvador, enter a future date so the form can save. The card may show an earlier printed expiration date. The system will not accept an expired date.
  2. Section 2 (Expiration Date): Enter the same date as Section 1. Do not enter the date printed on the card if that date has been superseded by a USCIS notice or, for El Salvador, by the country-page alert.
  3. Section 2 > Additional Information: Select the Section 2 tab on the right-hand side of the form, then select Additional Information. Type the note using the country-specific format below, then select Save Changes:
    • Sudan: "TPS for Sudan: A-12/C-19 EAD with USCIS extension notice through Oct. 19, 2026. No termination or new date published as of Oct. 19, 2026. April 19, 2027 entered as a placeholder pending USCIS announcement. Country page attached."
    • Ukraine: "TPS for Ukraine: A-12/C-19 EAD with USCIS extension notice through Oct. 19, 2026. No termination or new date published as of Oct. 19, 2026. April 19, 2027 entered as a placeholder pending USCIS announcement. Country page attached."
    • El Salvador: "El Salvador TPS: USCIS country-page alert states Salvadoran individuals present in the U.S. under TPS retain protection including work authorization until a further announcement. No new auto-extension or termination date published. Expired A12/C19 EAD accepted with this note. Country page attached."

    The seven post-Mullin terminated designations (Yemen, Haiti, Syria, Burma, South Sudan, Somalia, Ethiopia) are terminated. Do not enter a court order or extension notice for these countries. Reverify the employee on Supplement B using a currently valid List A or List C document. Venezuela 2023 documents stopped being valid after October 2, 2026, so run Supplement B for those as well. Lebanon (expires November 27, 2026) is still active but not covered by an EAD extension notice; enter the printed expiration date and watch USCIS as November 27 approaches.

  4. Attach supporting documents: Attach the current USCIS extension notice and the country-specific USCIS TPS webpage to the I-9 record.
  5. E-Verify: If you use E-Verify, enter the operative date when creating the case, regardless of what is printed on the employee's card. E-Verify applies to new hires only; do not open an E-Verify case at reverification.

Finding affected employees in i9 Intelligence: Open the Expiring Documents dashboard, or run the report at Reports > Compliance > Expiring Docs Report. Filter for EADs with category code A12 or C19. Cross-reference each record against the country's row in the Quick Reference table above to determine whether reverification, an operative-date update, or no action is required. Update the existing record. Do not create a new I-9.

Older Form I-9 versions (before version 8, which introduced the Additional Information box) require you to upload the country-specific note as an attached document instead. Other electronic I-9 platforms: if Section 1 requires a date value, enter the operative date and document the court order in Section 2's Additional Information box or as an attachment.

TPS-Based EAD Automatic Extensions: What Changed

Separate from the country-specific operative dates in the Quick Reference table, the underlying rules for automatic EAD extensions have changed. If you have employees who filed to renew a TPS-based EAD, the automatic extension rules may not match what appears on their I-797C receipt notice.

Three events have reduced or eliminated automatic extension periods for TPS-based EADs:

  1. Federal Register notices for specific TPS countries may set their own extension limits.
  2. The One Big Beautiful Bill Act (H.R. 1), implemented July 22, 2025, capped TPS-based EAD extensions at 1 year or the duration of the TPS designation, whichever is shorter, even for renewals that were already pending.
  3. The DHS interim final rule, effective October 30, 2025, eliminated automatic extensions entirely for new EAD renewal filers.

This creates three categories based on when the renewal application was received by USCIS:

Renewal Received By USCISAutomatic Extension Rule
On or before July 21, 2025Up to 540 days applies, but any portion of the extension that falls after July 22, 2025 cannot last longer than 1 year from that date or the TPS designation period, whichever is shorter.
July 22: October 29, 2025Limited to 1 year or the duration of the TPS designation, whichever is shorter. Not 540 days, even if the I-797C receipt notice shows the full 540-day extension.
October 30, 2025 or laterNo automatic extension. The employee's EAD is not extended while the renewal is pending.

Why this matters: Employees in the middle category may be holding I-797C receipt notices that show a 540-day extension period. That extension is no longer valid at its full length. The law changed after the notice was issued. Employers cannot rely on the date printed on the receipt notice alone. Check the "Received Date" on the I-797C and apply the rules above.

For more detail on EAD automatic extensions and the October 2025 cutoff, see our EAD Card guide and Auto-Extension Compliance Guide.

What Employers Should Do Now

The priority compliance checklist:

  1. Audit by EAD category code, not by nationality. Pull every Form I-9 with an EAD bearing category code A(12) or C(19). Those are the TPS-based work authorization codes. Do not pull records by country of birth. Country-of-birth audits create anti-discrimination liability under 8 U.S.C. § 1324b, enforced by the DOJ Immigrant and Employee Rights Section (IER).
  2. For the seven terminated post-Mullin countries (Yemen, Haiti, Syria, Burma, South Sudan, Somalia, Ethiopia): run the reverification workflow. A12 and C19 EADs are no longer valid regardless of the date printed on the card. Complete Supplement B on the existing I-9 with a currently valid List A or List C document the employee chooses; if the employee cannot produce one, employment cannot continue. For El Salvador: do not reverify off solely because September 9, 2026 passed. Enter a future date, note the USCIS country-page alert in Additional Information, and attach a dated copy of the country page. For Sudan and Ukraine: same process as El Salvador. Enter April 19, 2027 as a placeholder, note the extension notice and country page in Additional Information, attach a dated copy of the country page, and check both country pages before taking any reverification step. For Venezuela 2023: documents stopped being valid after October 2, 2026, so run Supplement B. For Lebanon (expires November 27, 2026): enter the card's printed expiration date and watch USCIS as that date approaches.
  3. Save the USCIS Alert and country-specific TPS webpage. USCIS explicitly permits attaching the downloaded Alert and TPS country webpage to the Form I-9. Do so to document your compliance posture.
  4. Do not take adverse action before authorization actually lapses. For El Salvador, USCIS currently says work authorization continues until a further announcement. Terminating a covered Salvadoran TPS employee because September 9 passed creates 8 U.S.C. § 1324b exposure. Sudan and Ukraine reach October 19 with no termination published, so don't act on the September 3 "set to terminate" line until DHS posts an end date. Lebanon employees remain authorized through the printed expiration date. For the seven terminated countries and Venezuela 2023, employment can continue only if the employee produces a valid List A or List C document during reverification.
  5. Watch for the next USCIS announcement on El Salvador, Sudan, Ukraine, and Lebanon. El Salvador is waiting on a further announcement with no published date. Sudan and Ukraine hit October 19 without a published decision, and Lebanon's next date is November 27. Have your Supplement B process ready to run at short notice once USCIS publishes an actual end date.
  6. Check EAD renewal filing dates. If any TPS employees filed EAD renewals between July 22 and October 29, 2025, their automatic extension is shorter than what the I-797C receipt notice shows. Check the "Received Date" on the receipt and apply the rules in the EAD automatic extension section above.
  7. Alert affected employees as a referral to counsel, not a termination warning. Employees facing work authorization loss need lead time for alternative pathways (H-1B, L-1, family petitions, adjustment of status, asylum, cancellation of removal). Frame every communication as a referral to immigration counsel, not a countdown to termination.
  8. Subscribe to USCIS updates. Sign up for E-Verify and Form I-9 GovDelivery alerts to receive official guidance as it is published.

"Seven TPS designations are terminated post-Mullin. That is the reverification queue: every A(12) and C(19) EAD on file from Yemen, Haiti, Syria, Burma, South Sudan, Somalia, or Ethiopia is no longer valid, and continuing to employ someone who cannot produce a new List A or List C document creates knowing-hire exposure. El Salvador is the exception sitting on the USCIS country-page alert. No new date. Work authorization continues until they announce otherwise. For the four still-active designations with printed expirations (Venezuela 2023, Sudan, Ukraine, Lebanon), the playbook is monitor and audit. Run the audit before enforcement resources arrive, not after," says Patricia Duarte, Director of Compliance at i9 Intelligence.

Need Help Managing TPS Reverifications?

Managing reverifications across seven post-Mullin terminations and Venezuela 2023, plus El Salvador, Sudan, and Ukraine populations with no published end date, is a full-time job. i9 Intelligence tracks expiring documents automatically, and our compliance team has 28 years of experience with situations exactly like this.

Schedule a Free Compliance Call. Our team will help you identify affected employees and walk you through the reverification process for each country.

Phone: (713) 668-6200 (Monday to Friday, 8 AM to 5 PM CT)
Email: support@i-9intelligence.com
Ticket: Submit a ticket

Frequently Asked Questions

What is TPS?

Temporary Protected Status (TPS) is a designation that allows nationals of certain countries to live and work in the United States when conditions in their home country (armed conflict, natural disaster, or other extraordinary circumstances) make it unsafe to return. TPS beneficiaries receive Employment Authorization Documents (EADs) that employers must accept as valid List A documents for Form I-9 purposes. For a full explanation, see our guide: What Is Temporary Protected Status?

What date do I enter on Form I-9 for TPS EADs?

For the seven terminated post-Mullin countries (Yemen, Haiti, Syria, Burma, South Sudan, Somalia, Ethiopia), A12 and C19 EADs are no longer valid. Reverify affected workers on Supplement B. For El Salvador, USCIS has not published a new date. Enter a future date so the electronic I-9 can save, note the country-page alert in Additional Information, and attach a dated copy of the page. Venezuela 2023 documents stopped being valid after October 2, 2026, so reverify those on Supplement B too. Sudan and Ukraine EADs paired with the USCIS extension notice were covered through October 19, 2026, and until USCIS posts a later date, enter April 19, 2027 as a placeholder with the Additional Information note and the country page attached. For Lebanon, enter the printed expiration date. USCIS publishes Friday updates, so operative dates can shift week to week.

What did the Supreme Court's Mullin v. Doe ruling do?

The June 25, 2026 ruling in Mullin v. Doe, 609 U.S. ___ (2026), held that federal courts cannot block DHS from terminating TPS designations. USCIS characterizes each country's operative date as "limited relief until the lower courts align with the U.S. Supreme Court's favorable decision in Mullin v. Doe." As each district court dissolves its stay under that ruling, USCIS is expected to issue country-specific follow-up dates. For a full strategic breakdown, see After Mullin v. Doe: The HR Playbook for Every TPS Termination.

Can I fire an employee when their TPS-based EAD expires?

No, you must reverify first, and only if authorization has actually lapsed. For El Salvador, USCIS currently says work authorization continues until a further announcement. Do not fire a covered Salvadoran TPS employee because September 9, 2026 passed. For a terminated designation, ask the employee to present a new List A or List C document showing continued work authorization; if they can, record it in Supplement B and continue employment. If they cannot, employment cannot continue. Terminating early based on TPS status or national origin violates 8 U.S.C. § 1324b.

My employee's I-797C says their EAD is extended for 540 days. Is that still accurate?

Not necessarily. The One Big Beautiful Bill Act (H.R. 1), implemented July 22, 2025, shortened automatic extensions for TPS-based EADs. If the renewal application was received by USCIS between July 22 and October 29, 2025, the extension is limited to 1 year or the TPS designation period, whichever is shorter, not 540 days. The I-797C receipt notice may still show the full 540-day extension because it was issued before the law changed. Check the "Received Date" on the I-797C and refer to the EAD automatic extension section above for the rules that apply to each filing window.

What happens if an active TPS designation isn't extended by its expiration date?

Check the country page before you treat the designation as lapsed. El Salvador is the current example. September 9, 2026 passed without a Federal Register extension or termination. USCIS posted an alert that Salvadoran TPS holders retain protection, including work authorization, until a further announcement. That isn't a lapse, and Sudan and Ukraine reach the same point on October 19, 2026. Hold off on Supplement B until DHS publishes an end date, and track each country's USCIS page daily around the expiration. If a stay is later issued, USCIS publishes a follow-up bulletin restoring work authorization for a limited period. See the expiration playbook above for the full 60/30/14/0-day cadence.

Did El Salvador TPS terminate on September 9, 2026?

No. The September 3, 2026 I-9 Central news item said the designation and related benefits were set to terminate on September 9, 2026, and told employers to enter that date for qualifying A12/C19 EADs paired with a USCIS extension notice. September 9 passed. USCIS did not publish a Federal Register termination or a new extension. The live instruction is the alert at the top of the El Salvador TPS country page: an announcement will be made at the appropriate time, and until then Salvadoran individuals present in the U.S. under TPS retain protection including work authorization. Do not reverify off solely because September 9 passed. The September 3 I-9 Central item has not been updated to match the country-page alert.

My TPS employee has an unrestricted Social Security card. Can I use it for reverification when the EAD expires?

Reverification is a document exam, not a status investigation. Look at the face of the card.

  • Restricted card (any of these legends is not List C: VALID FOR WORK ONLY WITH DHS AUTHORIZATION, VALID FOR WORK ONLY WITH INS AUTHORIZATION, NOT VALID FOR EMPLOYMENT). Reject it. Ask the employee to choose a different List A or List C document. The same rule applies if the card is laminated, even if unrestricted. For a terminated TPS designation, the replacement document is required on or before the termination-effective date shown in the Quick Reference table above. Background on the three restricted card types: "Valid for Work Only with DHS Authorization" on the I-9.
  • Unrestricted card, reasonably appears genuine and relates to the employee. It is a List C document. Record it on Supplement B. Employment may continue. Do not also demand a current EAD or other DHS document. Do not ask how a TPS holder obtained an unrestricted card.
  • Does not reasonably appear genuine (altered, doesn't relate to the person). Reject on that I-9 standard, then the same List A or List C deadline applies. Do not reject a card because the employee is Salvadoran or a known TPS holder.

USCIS, almost word for word (use this, do not paraphrase it away):

  • M-274 FAQ 10: EAD expired, employee shows a Social Security card → if unrestricted, no current DHS document required; if restricted, reject and they choose another List A or List C document.
  • M-274 §6.1: The employee must present current authorization from List A or List C, including an unrestricted Social Security card.

Why the pairing looks unusual. The Social Security Administration issues unrestricted cards to citizens, nationals, lawful permanent residents, asylees, refugees, and COFA citizens, not to TPS beneficiaries. TPS cards are usually restricted. El Salvador TPS has run since 2001, so a real unrestricted card can mean later LPR or asylum status, an older SSA issuance, or (most often) a restricted card that no one read closely. The employer inspects the card. The employer does not audit the person's immigration history.

IER guardrails that must stay in. Audit and reverify by A(12) or C(19) category code, not by country of birth. Do not specify which document the employee must present. Do not treat "this employee is TPS, so this card must be fake" as the reject reason.

In i9 Intelligence: Complete Supplement B on the existing record. Do not open a new I-9. Use the Expiring Documents dashboard (or the Expiring Docs Report under Reports > Compliance) and filter by A(12) or C(19) to match affected employees to the Quick Reference row.

What if my employee has TPS from a country not covered in the workflows above?

Every currently designated TPS country is listed in the Quick Reference table above, organized by status (terminated post-Mullin, pending further announcement, active with upcoming 2026 expiration, or terminated earlier in 2025). Match the employee's country to its row for the operative date, Federal Register cite, and any governing court case. For live USCIS guidance on any specific country, see the USCIS TPS page.