"Valid for Work Only with DHS Authorization" — What It Means for I-9

Document Verification
Form I-9
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What Does "Valid for Work Only with DHS Authorization" Mean?

If a new hire hands you a Social Security card that says "VALID FOR WORK ONLY WITH DHS AUTHORIZATION," you cannot accept it as a List C document on Form I-9. This is one of three restricted Social Security card types that the Social Security Administration (SSA) issues to noncitizens whose work authorization is tied to their immigration status.

The restriction means the cardholder was authorized to work in the United States only for a specific period or under specific conditions set by the Department of Homeland Security (DHS). While the card confirms the person has a Social Security number, it does not establish employment authorization on its own — which is exactly what List C documents are supposed to do.

This is a common point of confusion for employers completing Form I-9. Knowing how to handle restricted Social Security cards correctly protects your company from I-9 violations and helps you avoid unintentional discrimination.

Social Security Card Types and I-9 Acceptability

The SSA issues four types of Social Security cards. Only one is acceptable as a List C document for Form I-9. This table covers every card type, who receives it, and exactly how to handle it during the I-9 process:

Card TypeWho Receives ItList C Eligible?E-Verify SSN Required?Employer Action
Unrestricted (no notation)U.S. citizens, lawful permanent residents, refugees, asylees, noncitizen nationals, Compact of Free Association citizensYes (if not laminated)YesAccept as List C document. Record in Section 2.
VALID FOR WORK ONLY WITH DHS AUTHORIZATIONNoncitizens with temporary DHS work authorization (H-1B, TPS, DACA, parolees, etc.)NoYesReject for I-9. Ask employee to choose a different List A or List C document.
VALID FOR WORK ONLY WITH INS AUTHORIZATIONSame as above — older version issued before DHS replaced INS in 2003NoYesReject for I-9. Same rule as DHS version.
NOT VALID FOR EMPLOYMENTNoncitizens admitted without work authorization (SSN issued for non-work purposes such as government benefits)NoYesReject for I-9. Ask employee to choose a different List A or List C document.

Source: USCIS Acceptable Documents for Form I-9 and M-274 Handbook for Employers, Sections 4 and 13.

Who Receives a Restricted Social Security Card?

Unrestricted Social Security cards — the only type acceptable as List C documents — are issued only to:

  • U.S. citizens
  • Noncitizen nationals of the United States
  • Lawful permanent residents
  • Refugees
  • Asylees
  • Citizens of the Republic of the Marshall Islands, the Federated States of Micronesia, or the Republic of Palau admitted under a Compact of Free Association

Everyone else who receives a Social Security number — including noncitizens with temporary work visas (H-1B, L-1, TN, etc.), TPS holders, DACA recipients, and parolees — receives a restricted card. This doesn't mean they can't work. It means their work authorization comes from DHS, not from the Social Security card itself.

"The restricted Social Security card is one of the most misunderstood I-9 documents I see," says Patricia, Director of Compliance at i9 Intelligence. "HR sees a valid SSN on a government-issued card and assumes it works for List C. It doesn't. The notation — 'valid for work only with DHS authorization' — is a flag that this person's work authorization lives somewhere else: a DHS-issued EAD, a foreign passport with I-94, a permanent resident card if their status has changed. The card confirms the SSN, not the authorization."

Can You Accept a Restricted Social Security Card for I-9?

No. According to the USCIS Handbook for Employers (M-274), restricted Social Security cards are not acceptable List C documents. If an employee presents a restricted card during the I-9 process, you must ask the employee to provide a different document from either List A or List C.

This applies to both initial verification (Section 2) and reverification (Supplement B). Per M-274 Section 14: "If the employee presents a restricted Social Security card, you must reject it since it is not an acceptable Form I-9 document and ask the employee to choose a different document from List A or C."

One additional rule: even unrestricted Social Security cards must not be laminated to be acceptable for I-9.

The Cost of Getting This Wrong

Accepting a restricted Social Security card as a List C document is an automatic I-9 paperwork violation. Under current penalty amounts (effective January 2025 per 8 CFR § 274a.10), each violation carries a fine of $288 to $2,861 per Form I-9.

To put that in perspective: an employer who incorrectly accepts restricted Social Security cards from 10 new hires faces $2,880 to $28,610 in paperwork fines alone. If any of those workers are also found to be unauthorized, knowing-hire penalties of $716 to $5,724 per worker apply on top — bringing the total exposure for 10 workers to $10,040 to $85,850.

For a full breakdown of every current penalty amount and how ICE calculates fines, see I-9 Penalties in 2026: Every Fine Amount Employers Need to Know.

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What to Do When an Employee Presents a Restricted Card

If a new hire presents a Social Security card with any of the three restricted notations, follow these steps:

  1. Do not accept the card as a List C document. Politely explain that restricted Social Security cards cannot be used for Form I-9 verification.
  2. Ask the employee to choose a different document. They can present any acceptable document from List A (which covers both identity and work authorization) or a different List C document paired with a List B identity document.
  3. Do not specify which document to present. Telling an employee which specific document to show — rather than letting them choose — can be considered document abuse and may violate anti-discrimination provisions under INA Section 274B.
  4. Give the employee time. Remember, employees have until the third business day after their start date to present Section 2 documents. If they need to obtain a different document, they have that window.
  5. Document the interaction. Note that the restricted card was presented and a replacement document was requested. This shows good-faith compliance if your I-9s are ever audited.

When the Employee's Status Has Changed

A restricted Social Security card reflects the person's immigration status at the time the card was issued — not today. Many employees with restricted cards have since gained permanent work authorization, but they still carry the old card in their wallet because the SSN on it is still valid for tax and banking purposes.

Common scenarios:

  • H-1B → lawful permanent resident. An H-1B holder received a restricted card when they first got their SSN. Years later, they adjusted status and became a permanent resident. Their old restricted card still works at the grocery store and for tax purposes — but not for I-9 List C. For the I-9, they should present their permanent resident card (List A) or apply for a replacement unrestricted Social Security card through the SSA.
  • TPS → adjustment of status applicant. Similar story — the employee moved from TPS to a pending green card application. They have an EAD now, which is a List A document. The old restricted SSN card is irrelevant to the I-9.
  • Noncitizen → naturalized U.S. citizen. Once naturalized, the employee is eligible for an unrestricted Social Security card through the SSA — but they have to apply for the replacement. Until they do, they should present other acceptable documents (U.S. passport, Certificate of Naturalization, or a List B + List C combination that doesn't rely on the old restricted card).

Your only question during the I-9 is whether the document in front of you is acceptable for List A, B, or C as it appears today. The employee's status history and what documents they could present are not relevant to the form. You evaluate only what's presented. If the restricted card is what they hand you, you cannot accept it — regardless of whether they now have other documents in their file or at home.

Restricted Social Security Cards and E-Verify

Even though you cannot accept a restricted Social Security card as a List C document, you must still enter the employee's Social Security number in E-Verify. Per USCIS guidance: "Although these cards are not acceptable to demonstrate employment authorization, employers using E-Verify must still enter the Social Security number when creating the case."

The employee will provide their SSN in Section 1 of Form I-9 (which they complete themselves). E-Verify uses this number to verify employment authorization through the SSA and DHS databases — regardless of which documents the employee presented for Section 2.

For more on how E-Verify works with Form I-9, see our E-Verify overview.

Common Employer Mistakes with Restricted Social Security Cards

These are the mistakes we see most often when employers encounter restricted cards:

  • Accepting the restricted card as a List C document. This is the most common error. During an I-9 audit, an examiner will flag any restricted Social Security card recorded in the List C section — it's an automatic violation.
  • Refusing to hire the employee. A restricted card does not mean the person is unauthorized to work. They may have valid work authorization through other documents (EAD, foreign passport with I-94, etc.). Refusing to hire based solely on a restricted card could constitute discrimination.
  • Telling the employee which document to bring instead. You must let the employee choose which acceptable document to present. Directing them to bring a specific document is considered document abuse.
  • Not entering the SSN in E-Verify. Even when you reject the card for I-9 purposes, the SSN itself is still valid and required for E-Verify case creation.
  • Confusing the restriction with employment eligibility. The card restriction reflects the person's immigration status at the time the card was issued. Their status may have changed since then — for example, someone who received a restricted card as a TPS holder may have since become a lawful permanent resident.
  • Trusting the HCM platform to catch it. Most HCM onboarding modules (Workday, UKG, ADP, BambooHR) accept any Social Security card image or SSN entry at face value — they don't parse for the "VALID FOR WORK ONLY WITH DHS AUTHORIZATION" notation. If your workflow is "employee uploads their documents and the HCM moves them through onboarding automatically," a restricted card will pass through every time. The compliance check is always on the employer's side.

Frequently Asked Questions

What's the difference between "Valid for Work Only with DHS Authorization" and "Not Valid for Employment"?

Both are restricted Social Security cards and neither is acceptable for I-9. The difference is in who receives them. "Valid for Work Only with DHS Authorization" goes to noncitizens who have temporary work authorization from DHS. "Not Valid for Employment" goes to noncitizens who were issued an SSN for non-work purposes — such as receiving certain government benefits. In both cases, the employee must present a different document for I-9 verification.

Can I reject an employee who only has a restricted Social Security card?

No. You cannot refuse to hire someone because their Social Security card is restricted. The card restriction does not determine whether someone is authorized to work — it only means that particular card cannot serve as a List C document. The employee may have other valid documents (such as an Employment Authorization Document or a foreign passport with I-94) that establish their work authorization.

Does a restricted Social Security card mean the person can't work in the U.S.?

Not necessarily. Many people with restricted cards are fully authorized to work. The restriction means their work authorization comes from DHS rather than from their citizenship or permanent resident status. H-1B visa holders, TPS beneficiaries, DACA recipients, and many other noncitizens with valid work authorization receive restricted Social Security cards.

What if the employee's immigration status has changed since the card was issued?

An employee who was issued a restricted card may have since become a lawful permanent resident or even a U.S. citizen. However, the old restricted card is still not acceptable for I-9 purposes. The employee would need to present a different acceptable document — such as their Permanent Resident Card (List A), unrestricted Social Security card (List C), or U.S. passport (List A).

Do I need to check Social Security card restrictions during reverification?

If an employee presents a Social Security card during reverification (Supplement B), you must verify it is unrestricted. Per M-274: if the employee presents a restricted Social Security card during reverification, you must reject it and ask the employee to choose a different document from List A or List C. The same rules apply as during initial Section 2 verification.

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