3 Reverification Facts That Surprise Even Experienced HR Teams
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The current Form I-9 edition is dated 01/20/25 with an expiration of 05/31/2027. After July 31, 2026, employers must use this edition exclusively — earlier 08/01/2023 forms with the 07/31/2026 expiration will no longer be acceptable for new hires.
Most HR teams have heard the form changed. The harder question is whether the copy in their hiring packet, HRIS, or electronic I-9 system is actually the current version. This guide shows you how to verify the edition you're using, where to find the edition date on the form, and what to do if a self-audit turns up old-edition Forms I-9.
Three things are happening at once in 2026 that make edition verification higher-stakes than in past years.
Two valid forms are in circulation right now. USCIS published the 01/20/25 edition with a 05/31/2027 expiration, but the prior 08/01/2023 edition is still acceptable through its printed expiration of 07/31/2026. HR teams handling new hires today may encounter either version — and may have stockpiled the older one without realizing a newer edition exists.
The July 31, 2026 transition deadline is months away. Per USCIS, on August 1, 2026, employers must only use the Form I-9 version with the 05/31/2027 expiration date. Any organization still serving the 07/31/2026-expiration form after that date is using a non-current version.
ICE updated its I-9 inspection fact sheet in March 2026 with stricter electronic-system standards. "Using a Form I-9 version that was not current at the time of completion" remains a technical violation under the latest ICE fact sheet, but technical violations only get a 10-business-day correction window — and only if you catch them before an inspector does. Uncorrected, they convert to substantive.
To verify the Form I-9 you're holding is the current edition, look at the bottom-left corner of the form — not the expiration date at the top. This is the explicit instruction USCIS publishes on its Self-Audits and Correcting Mistakes page.
Two dates appear on every Form I-9, and they are not the same thing:
The expiration date is what trips employers up. It is a form-edition expiration — the date USCIS approval for that version of the form runs out. It has nothing to do with employee work authorization, document expiration, or how long you retain the completed form.
The current Form I-9 edition is 01/20/25, valid through 05/31/2027. USCIS published this revision with relatively minor changes compared to the major August 2023 overhaul, but the changes are real and they affect how Section 1 reads.
The most visible change: the Section 1, Box 4 attestation language changed from "A noncitizen authorized to work" back to "An alien authorized to work," reverting to the statutory language used in the Immigration and Nationality Act. Forms completed on the 08/01/2023 edition with the "noncitizen" language remain valid — you do not need to redo them.
For the comprehensive walk-through of Section 1, Section 2, Supplement A, and Supplement B on the current form, see our complete guide to the current Form I-9 in 2026.
Two editions are currently acceptable for new completions; the rest are historical and should not appear on any I-9 completed in 2026.
| Edition Date | Expiration on Form | Status for New Hires in 2026 |
|---|---|---|
| 01/20/25 | 05/31/2027 | Current edition. Acceptable for all new hires. Required after July 31, 2026. |
| 08/01/2023 | 07/31/2026 or 05/31/2027 | Acceptable through 07/31/2026 if expiration shows 07/31/2026. The 05/31/2027 reprint remains acceptable. |
| 10/21/2019 | 10/31/2022 (extended) | Not acceptable for new completions. Old records stay in retention. |
| 07/17/2017 | 08/31/2019 | Not acceptable. Historical only. |
| 11/14/2016 | 08/31/2019 | Not acceptable. Historical only. |
| 03/08/13 and earlier | Various | Not acceptable. May appear in long-retention files for pre-2017 hires. |
The 08/01/2023 edition is unusual: USCIS approved a re-issue of the same edition with an extended expiration date. Two printings exist — one shows 07/31/2026 in the upper-right, the other shows 05/31/2027. Both are the same edition; only the expiration approval differs.
Note: If you are stocking paper Forms I-9 in a hiring packet, the safest move today is to discard any pre-printed copies showing an expiration date of 07/31/2026 and replace them with the 01/20/25 edition (expiration 05/31/2027). Doing this before August 1, 2026 prevents a situation where your hiring packet contains a non-current form on the day a new employee fills it out.
The fastest way to know whether your organization has an edition problem is to run a structured self-audit on a representative sample of your active I-9s. Edition mistakes show up most often in two places: paper Forms I-9 printed before the 01/20/25 release that nobody refreshed, and electronic I-9 systems still serving the older form template to new hires. Schedule a free compliance call to walk through your sample with our team, or use the I-9 Risk Calculator for a quick exposure estimate.
Per USCIS, on August 1, 2026, employers must only use the Form I-9 version with the 05/31/2027 expiration date. Any I-9 completed on or after that date using a form showing the 07/31/2026 expiration is non-current at the time of completion.
What this means in practice:
Per the March 2026 ICE fact sheet, using a non-current edition is a technical violation — ICE must give 10 business days to correct before assessing a fine. Uncorrected, it converts to substantive. "We used the wrong form for six months" is not a strong audit-prep position across a large workforce.
"The mistake we see most often isn't malicious — it's just stale," says Patricia Duarte, Director of Compliance at i9 Intelligence. "Someone printed 200 copies of Form I-9 in 2024, stuck them in the new-hire binder, and nobody refreshed it. By the time we audit, half the I-9s are on a version USCIS replaced. Walking through the bottom-left corner of every form in a sample is a 30-minute exercise that prevents a much bigger conversation later."
If your organization uses an HCM or stand-alone I-9 system — Workday, SAP SuccessFactors, ADP, UKG, Tracker, or another vendor — the system generates the I-9 electronically. That doesn't mean you're automatically on the current edition. Vendors deploy form-edition updates on their own release schedules, and multi-month gaps between USCIS publishing a new edition and HCMs rolling it out to all customers are common.
Three checks to run with your electronic I-9 vendor:
If your vendor's answers are unsatisfactory, escalate inside the vendor or move the I-9 process out entirely. Talk to our team about how clients have handled migration off Workday, SAP, ADP, and UKG I-9 modules.
You do not redo a Form I-9 because the edition was retired after the form was completed. Per USCIS, Forms I-9 completed on a previous valid edition remain valid records. You only have an issue if you used a non-current edition on the day of completion.
What to do depends on what the audit turned up:
For a full walk-through of self-audit sample size, sequencing, and documentation, see our I-9 self-audit playbook for 2026.
No. Forms I-9 completed on the 08/01/2023 edition while it was valid remain valid records. USCIS has not asked employers to retroactively reissue I-9s when a new edition is published. Keep the original in retention; complete new I-9s for new hires using the current 01/20/25 edition.
Using a Form I-9 version that was not current at the time of completion is a technical or procedural violation under the March 2026 ICE I-9 inspection fact sheet. ICE must give the employer at least 10 business days to correct before assessing a fine. Uncorrected, it becomes a substantive violation. The fix: complete a new Form I-9 on the current edition and attach it to the original with a brief memo.
The edition date (sometimes labeled "revision date" or "Rev.") is printed in the bottom-left corner of every page of Form I-9. The expiration date is printed in the upper-right corner. USCIS instructs employers to use the bottom-left edition date — not the expiration date — to determine which version of the form they have.
It shouldn't. After July 31, 2026, only Forms I-9 with the 05/31/2027 expiration are acceptable. If your HCM generates I-9s with the 07/31/2026 expiration on or after August 1, 2026, that's a vendor compliance failure that becomes your problem in an ICE inspection. Confirm in writing with your vendor that the 01/20/25 edition is the only template being served on or after the deadline.
Yes, with conditions. The 08/01/2023 edition with a 05/31/2027 expiration date remains acceptable. The 08/01/2023 edition with a 07/31/2026 expiration is acceptable only through July 31, 2026 — after that, employers must use forms showing the 05/31/2027 expiration.
If you stock paper Forms I-9, yes — download the current 01/20/25 edition directly from USCIS.gov. Always pull the form from USCIS rather than a third-party site. Refresh at least quarterly so your hiring packet is never more than 90 days behind a USCIS update.
Edition verification is straightforward to do once and easy to forget for two years. i9 Intelligence has 27+ years of I-9 and E-Verify specialization. We handle remote Section 2 verification, full-record I-9 audits, and E-Verify enrollment for clients from 50-employee SMBs to enterprise organizations migrating off HCM-bundled I-9 modules.