This guide is built for HR leaders, legal teams, and compliance officers responsible for I-9 verification. We’ll break down the acceptable documents, verification deadlines, and what to do if something doesn’t look right—so your team stays ahead of ICE audits.
Under federal law, every new hire must provide documents that verify both their identity and authorization to work in the U.S. These documents must come from an official list published by the U.S. Citizenship and Immigration Services (USCIS).
The employer is legally responsible for:
• Collecting the right document(s)
• Reviewing them for authenticity
• Completing Form I-9 within 3 business days
Failure to do so = civil fines, potential criminal liability, and ICE audit risk.
There are three categories—List A, List B, and List C. Employees must present either one document from List A, or one each from Lists B + C.
One document from this list is enough.U.S.
• Passport (unexpired or expired)Permanent
• Resident Card (Green Card)Employment
• Authorization Document with photo
Must be paired with one List C document.
• Driver’s license or state ID
• School ID with photo
• Voter registration card
Must be paired with one List B document.
• Social Security Card (unrestricted)
• U.S. birth certificate
• Certificate of U.S. Citizenship
Under penalty of perjury, your I-9 sign-off means: “These documents appear genuine and relate to the person presenting them.”
You don’t have to be a forensics expert. But you must act with reasonable judgment. If it looks fake or doesn't match the name on the form, follow these steps:
• Name mismatch? Ask for explanation, memo the discrepancy
• Spelling errors? Request corrected form or supporting doc
• Multiple last names? Verify with employee, document rationale
• Clearly invalid? Politely reject and request alternate from same list
Yes. All documents used for Form I-9 must be unexpired at the time of review. Expired documents cannot be accepted, even if they previously satisfied requirements.
Employers must reject any documents that don’t reasonably appear to be genuine or relate to the employee. Request another document from the same list and memo any discrepancies in the employee’s I-9 file.
No. Asking for additional documentation beyond what’s required by law can result in claims of document abuse or discrimination. Only ask for the minimum acceptable combination (List A, or B + C).
You must physically examine the documents and complete Section 2 of the I-9 within 3 business days of the employee’s start date. Failure to meet this timeline can result in fines.
If an employee’s name on the document differs from their name on the I-9, ask for a reasonable explanation. If the explanation is acceptable, attach a memo explaining the discrepancy. In cases of legal name change, keep a copy of supporting proof.
You're not expected to be a document expert, but you are required to ensure documents reasonably appear genuine. If they clearly don’t, reject them.
Yes. If an employee cannot provide acceptable, unexpired documents within the required time frame, and does not present valid alternatives, you may lawfully terminate employment.
I-9 Intelligence automates this entire process for you.
• Smart workflows ensure correct document pairings
• Automated reminders for expiring work authorizations
• Built-in audit defense features and compliance reports
See how our platform supports your HR team from day one.
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