Form I-9 Supplement B: The Employer Guide to Reverification and Rehire
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A new hire slides a Social Security card across the counter. It's the plain blue-and-white kind, no legend printed on the front, laminated in the clear pouch the employee has kept it in since 1998. Whether that card is a valid List C document for the Form I-9 comes down to two things: what's on the face of the card, and whether the card has been laminated. Nothing about the employee's immigration status enters the analysis.
An unrestricted Social Security card is a Social Security Administration card with no restrictive legend printed on the face. If it's unrestricted, not laminated, and reasonably appears genuine and relates to the employee, it's a valid List C document for Form I-9 at initial hire and at reverification. That's M-274 Section 13, straight through. The complications are all on the other three types of card the SSA issues, which is why the term "unrestricted" appears on almost every restricted card article and almost never gets its own definition.
Look at the face of the card. Above the printed name and Social Security number, the SSA prints one of three legends, or nothing. "Nothing" is the unrestricted card. The three restrictive legends:
Any of those three legends and the card is not acceptable as a List C document. Reject it, and ask the employee to choose a different document from List A or List C. Detailed employer rules for the restricted variants live in our separate guide: "Valid for Work Only with DHS Authorization" on the I-9.
An unrestricted card has none of those legends on the face. Just the SSA seal, the printed name, the nine-digit Social Security number, a signature line, and the card issuance date on newer cards. That's the whole test at first glance.
SSA policy (POMS RM 10205.100) issues unrestricted cards to a specific set of people: those whose work authorization is permanent and doesn't depend on DHS granting it. That's six groups:
Everyone else who has ever received an SSN (every H-1B holder, every TPS beneficiary, every DACA recipient, every EAD-based worker) received a restricted card at the time of issuance. That's the design of the SSA card system: the legend on the face of the card records the person's status when the card was printed. It does not update when the person's status changes.
Which is why an employer's job at reverification is not to reconstruct an immigration history. If the card in front of you is unrestricted today, and it reasonably appears genuine and relates to the employee, you accept it. USCIS is explicit about this in M-274 FAQ 10: "If the employee presents an unrestricted Social Security card, the employee does not also need to present a current DHS document."
Yes, as a List C document, subject to two conditions and one non-condition.
The card cannot be laminated. A laminated Social Security card is not acceptable for I-9 purposes, even when unrestricted, and even when the employee has been carrying it in a plastic sleeve their entire adult life. This is the trap almost everyone misses. Reject the laminated card, explain the SSA doesn't authorize lamination, and ask the employee to choose a different List A or List C document. The SSA will issue a replacement card at no charge; a driver's license paired with a birth certificate or an unlaminated card that arrives later also works.
The card must reasonably appear genuine and relate to the employee. That's the M-274 standard, and it applies to every I-9 document. You are not a document expert. You are asked to accept documents that look real and match the person in front of you. Whiteout on the signature line, obvious tampering, or a card whose name plainly does not match the person: those are rejection grounds. "The name is Salvadoran and the employee has a TPS EAD in their file" is not a rejection ground; that would put you on the wrong side of INA 8 U.S.C. §1324b.
The employee's immigration status is not a condition. You do not demand a current EAD alongside an unrestricted SSA card. You do not ask how a TPS holder obtained an unrestricted card. You do not compare the card to what you know about their file. The document exam is the document exam. USCIS made this explicit in M-274 FAQ 10 precisely because employers were adding a status-verification step that isn't in the regulation.
Every document call we take starts with a photo. If you're looking at a Social Security card and can't tell whether it's acceptable, our compliance team will look at it with you and give you a straight answer, usually inside 30 minutes. Schedule a free compliance call, or run the situation through our I-9 Risk Calculator.
| Card face | Who receives it | List C at initial hire? | List C at reverification? |
|---|---|---|---|
| Unrestricted (no legend) | U.S. citizens, noncitizen nationals, LPRs, refugees, asylees, COFA citizens | Yes, if not laminated | Yes, if not laminated. No current DHS document required. |
| VALID FOR WORK ONLY WITH DHS AUTHORIZATION | H-1B, TPS, DACA, parolees, most EAD holders | No. Reject; ask for a different List A or C document. | No. Reject; ask for a different List A or C document. |
| VALID FOR WORK ONLY WITH INS AUTHORIZATION | Same as above; older version, pre-2003 | No. Same rule as the DHS version. | No. Same rule as the DHS version. |
| NOT VALID FOR EMPLOYMENT | Noncitizens who received an SSN for non-work purposes (benefits eligibility) | No. | No. |
Source: SSA POMS RM 10205.100; USCIS M-274 §13 (List C item 1) and M-274 FAQ 10. For every reject case, the employer must let the employee choose the replacement document from List A or List C. Telling them which document to bring is document abuse under INA 8 U.S.C. §1324b.
The situation that generates the most inbound questions: a TPS employee, or a former H-1B holder, or someone whose file shows a restricted card from years ago, presents an unrestricted card at reverification. The instinct is to treat it as a red flag. Don't.
Three benign explanations account for almost all of these:
The employer's job is not to reconstruct which explanation applies. The employer inspects the card. The employer does not audit the person's immigration history. Full application of this rule in the TPS reverification context (with El Salvador, Sudan, and Ukraine as live examples): TPS Status for Employers: I-9 and E-Verify Instructions by Country.
Four patterns show up in almost every audit we run when unrestricted cards are involved. Do not demand a current EAD or other DHS document alongside an unrestricted card; USCIS rejected that step in M-274 FAQ 10. Do not reject the card because the employee's file shows TPS or a prior restricted card; the current card is what governs. Do not tell the employee which replacement document to bring when you do reject a card (laminated, restricted, or not-genuine); the employee chooses from List A or List C. Do not open an E-Verify case at reverification just because a Social Security card is involved; E-Verify photo matching does not cover Social Security cards, and E-Verify is a new-hire tool, not a reverification tool.
"The unrestricted card call is almost always a phone call where an HR manager wants us to tell them not to accept it, because the file feels weird. Our answer is the same every time. Look at the face of the card. If the legend is not there and it's not laminated and it looks real and it matches the person, it is a List C document and you are done. The weirdness in the file is not your problem. That's SSA and USCIS's recordkeeping to reconcile, not yours," says Patricia Duarte, Director of Compliance at i9 Intelligence.
If you're holding a Social Security card and unsure whether to record it in List C, we do this every day. Send us a photo and we'll look at it with you.
Phone: (713) 668-6200 (Monday to Friday, 8 AM to 5 PM CT)
Email: support@i-9intelligence.com
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A Social Security Administration card with no restrictive legend printed on the face. Cards printed with VALID FOR WORK ONLY WITH DHS AUTHORIZATION, VALID FOR WORK ONLY WITH INS AUTHORIZATION, or NOT VALID FOR EMPLOYMENT are restricted. Anything else is unrestricted.
Yes, provided the card is not laminated and reasonably appears genuine and relates to the employee. That's the rule at initial verification (Section 2) and at reverification (Supplement B). You do not need to see a current EAD or any other DHS document alongside it.
Reject it. Laminated Social Security cards are not acceptable for Form I-9, even when unrestricted, because the SSA does not authorize lamination and the security features on the card can't be inspected through it. Ask the employee to choose a different List A or List C document. They can also request a free replacement card from SSA, which typically arrives within two weeks. That timing usually works with the three-day I-9 deadline if the employee acts the day of hire.
It's unusual, but it's not a rejection ground. Look at the face of the card. If it's unrestricted and reasonably appears genuine and relates to the employee, it's a valid List C document under M-274 FAQ 10 and §6.1. Do not demand a current EAD alongside it. Do not ask how they obtained the card. The most common benign explanation is that the employee's status changed after the card was originally issued (later LPR, asylum, or naturalization), or that the file's prior card was restricted and this is a newer replacement. Full context: TPS Status for Employers guide.
Yes. E-Verify uses the Social Security number the employee provided in Section 1, not the card itself. Even when you reject a restricted card as a List C document, the SSN behind it is still valid and required for E-Verify case creation. E-Verify photo matching applies only to U.S. passport, U.S. passport card, Permanent Resident Card (I-551), and EAD (I-766), and never to Social Security cards.