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Employee and employer steps have different deadlines

Form I-9 records the employer’s check of identity and permission to work in the United States. The employee completes and signs Section 1 by the first day of work, after accepting the job offer. The employer generally examines acceptable documents and completes Section 2 within three business days after that first day.

If employment lasts less than three business days, the employer’s examination and completion take place at hire instead, and a receipt cannot replace the required document. The regulation permits the employer, its agent or someone acting in its interest to perform the employer step. Arrange who will do it before work starts; ownership overseas does not change the deadlines or authorise an informal remote check.

Sources: Department of Homeland Security: §274a.2(b)(1)(i)–(iii), (b)(2)(i); alternative examination reference; targeted follow-up: 274a.2(b)(1)(i)–(iii),(ix), (b)(2)(i) U.S. Citizenship and Immigration Services: All four pages; Section1, Section2, document lists and Supplements A/B U.S. Citizenship and Immigration Services: All eight pages; employer/employee steps, document examination, representative liability, retention

A deadline does not establish a permitted checking method

The regulation recognises physical examination or an alternative procedure authorised under its specified conditions. A video call, emailed scan or overseas manager’s review is not automatically an authorised method. Use the official instructions to establish the applicable examination process before relying on it.

Make the form instructions and acceptable-document lists available to the employee, and let the employee choose which acceptable documents to present. The employer keeps the completed form; it is not mailed to U.S. Citizenship and Immigration Services (USCIS) or Immigration and Customs Enforcement (ICE). An authorised representative is someone the employer designates to complete its part. Choosing that person does not remove the employer’s responsibility for verification violations.

Sources: Department of Homeland Security: §274a.2(b)(1)(i)–(iii), (b)(2)(i); alternative examination reference; targeted follow-up: 274a.2(b)(1)(i)–(iii),(ix), (b)(2)(i) Department of Homeland Security: 2023-15533, II(A), IV(A)–(D) U.S. Citizenship and Immigration Services; public copy hosted by University of New England: All 8 pages, edition/footer and employer/document/retention instructions U.S. Citizenship and Immigration Services: All eight pages; employer/employee steps, document examination, representative liability, retention

Check the form version before the hire

The USCIS-hosted form recovered for this review carries edition 01/20/25 and a printed expiration date of May 31, 2027. These identify the form version; they are not an employee’s work-authorisation expiry or the date to destroy a completed I-9. Use the USCIS Form I-9 page to check accepted editions before preparing the hiring packet.

Sources: U.S. Citizenship and Immigration Services: All four pages; Section1, Section2, document lists and Supplements A/B U.S. Citizenship and Immigration Services: All eight pages; employer/employee steps, document examination, representative liability, retention

Keep the later of two retention dates

Retain the I-9 for three years after hire or one year after termination, whichever is later.

In a fictional example, an employee starts on January 15, 2027 and leaves on January 15, 2030. Three years after hire is January 15, 2030; one year after departure is January 15, 2031. The later date, January 15, 2031, controls this I-9 calculation. Other record-retention duties are separate.

Sources: Department of Homeland Security: §274a.2(b)(1)(i)–(iii), (b)(2)(i); alternative examination reference; targeted follow-up: 274a.2(b)(1)(i)–(iii),(ix), (b)(2)(i)

If your E-Verify provider uses web services

E-Verify’s 22 September 2026 bulletin gives web-services developers until 31 March 2027 to complete integration and acceptance testing for Interface Control Agreement version 32. It adds hiring-site information with each case and case-payload fields including software name and the remote-document-examination indicator. If your provider uses this connection, ask whether its software is on that path. This developer deadline does not itself require every employer to enroll in E-Verify.

Sources: U.S. Citizenship and Immigration Services, E-Verify official GovDelivery bulletin: Complete bulletin: web-services-developer adoption and deadline

Scope

  • The official four-page form and complete eight-page instructions for edition 01/20/25 were read. The central USCIS live accepted-edition list remained inaccessible, so this is not confirmation that no later edition or additional accepted edition exists.
  • This page does not determine individual work authorisation, E-Verify, anti-discrimination or visa-category questions.

Next step

Arrange a compliant examination process before the hire, and calculate both retention dates when employment ends.

Sources & review notes

The source records distinguish access dates from substantive review dates. Updating an explanation does not itself recheck the law.

8 CFR §274a.2: employment verification and record retention

Department of Homeland Security

Passage, dates and research notes

primary · §274a.2(b)(1)(i)–(iii), (b)(2)(i); alternative examination reference; targeted follow-up: 274a.2(b)(1)(i)–(iii),(ix), (b)(2)(i)

within three business days of the hire

Accessed: 2026-11-14T00:44:56.985055+00:00 · Meaning reviewed: 2026-11-14T00:50:01.831769+00:00 · Next review target: 2026-12-12

Prior AI-assisted review scope (2026-11-12): Read scoped employer/employee completion timing, short-duration hire exception, retention and reference to authorised alternative examination. Current USCIS I-9 instruction PDF returned 403; its current edition and detailed acceptable-document/remote-procedure instructions remain unverified. Do not use this guide as a substitute form. Targeted follow-up at 2026-11-14T00:50:01.831769+00:00: Read current scoped regulatory text. Current USCIS form/instructions403; public E-Verify updates403. Reginfo approval/pending-extension records do not establish the currently usable edition. Follow-up read scope: 274a.2(b)(1)(i)–(iii),(ix), (b)(2)(i). This follow-up does not assert a fresh complete review beyond that scope. The earlier reviewed range is preserved, with current form/CISA/docket limits unchanged unless expressly resolved above.

DHS 2023 authorisation of optional I-9 alternative procedure

Department of Homeland Security

Passage, dates and research notes

primary · 2023-15533, II(A), IV(A)–(D)

participants in good standing

Accessed: 2026-11-14T00:44:56.984575+00:00 · Meaning reviewed: 2026-11-14T00:50:01.831769+00:00 · Next review target: 2026-12-14

Read actual authorisation: E-Verify eligibility by hiring site, copies+live video+notation+clear copies+inspection availability; nondiscrimination/consistent use and employee physical-presentation option. Not current edition confirmation. Review is limited to 2023-15533, II(A), IV(A)–(D). No human or professional legal review is claimed.

USCIS Form I-9 instructions edition01/20/25: complete public copy

U.S. Citizenship and Immigration Services; public copy hosted by University of New England

Passage, dates and research notes

primary · All 8 pages, edition/footer and employer/document/retention instructions

Employers cannot ask employees for documentation to verify information entered in Section 1

Accessed: 2026-11-14T01:48:31.419661+00:00 · Meaning reviewed: 2026-11-14T02:06:27.232101+00:00 · Next review target: 2026-12-14

Complete 8-page USCIS-authored instructions PDF read, honestly identified as a university-hosted copy. Edition01/20/25 and expiration05/31/2027 visible. Central USCIS latest-edition page/PDF access remains blocked; this copy is not proof of an exhaustive latest-instruction review. No individual work permission or automatic-extension entitlement inferred.

E-Verify ICA v32 adoption bulletin,22 September 2026

U.S. Citizenship and Immigration Services, E-Verify official GovDelivery bulletin

Passage, dates and research notes

primary · Complete bulletin: web-services-developer adoption and deadline

Software integration and acceptance testing must be completed by Mar. 31, 2027

Accessed: 2026-11-14T01:42:48.534870+00:00 · Meaning reviewed: 2026-11-14T02:06:27.233802+00:00 · Next review target: 2026-12-14

Full official bulletin read. It concerns web-services developers, new hiring-site/case payload details and software adoption; not a new enrollment duty on every employer. No private staging/production account accessed.

USCIS Form I-9, edition 01/20/25, official four-page form

U.S. Citizenship and Immigration Services

Passage, dates and research notes

primary · All four pages; Section1, Section2, document lists and Supplements A/B

Edition 01/20/25

Accessed: 2026-11-14T10:20:35Z · Meaning reviewed: 2026-11-14T10:26:26.384421+00:00 · Next review target: 2026-12-14

The complete actual USCIS-hosted four-page PDF body was read through the public web reader. It prints Expires 05/31/2027. This verifies this retrieved form, not the complete current accepted-edition list on the inaccessible landing page. Retained JSON also contains two failed opens; only its first official form body is the substantive source. The fetchedAt value records retention of the actual reader receipt, not original PDF download time.

USCIS Form I-9 instructions, edition 01/20/25, official eight-page instructions

U.S. Citizenship and Immigration Services

Passage, dates and research notes

primary · All eight pages; employer/employee steps, document examination, representative liability, retention

Employers are liable for any statutory and regulatory violations

Accessed: 2026-11-14T10:20:35Z · Meaning reviewed: 2026-11-14T10:26:26.384421+00:00 · Next review target: 2026-12-14

Actual USCIS-hosted instructions recovered by a fresh search result and immediate reader open of this observed query URL. All 8 pages were read, including anti-discrimination, liability, form steps, rehire/reverification, E-Verify and retention. This replaces reliance solely on a university copy for the dated text. The instruction itself directs users to /i-9 to ensure the latest edition; that live page remains403. The published citation uses the clean official PDF address; retrievalUrl retains the exact observed cached query route. The fetchedAt value records retention of the actual reader receipt, not a new direct download.

Detailed rule records (1)
Give the local employer an I-9 timing and retention owner Depends on the facts

Under §274a.2, Section 1 is completed at hire and the employer generally examines acceptable evidence and completes Section 2 within three business days of hire; employment lasting less than three business days has an at-hire rule. Employers retain the I-9 for three years after hire or one year after termination, whichever is later.

When to check: Give the local employer an I-9 timing and retention owner. Source review: 2026-11-12.

8 CFR §274a.2: employment verification and record retention USCIS Form I-9 instructions edition01/20/25: complete public copy E-Verify ICA v32 adoption bulletin,22 September 2026 USCIS Form I-9, edition 01/20/25, official four-page form USCIS Form I-9 instructions, edition 01/20/25, official eight-page instructions
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