Form I-9 Employment Verification Procedure template

2. Roles and responsibilities

• [HR/name/role]: owns this procedure, tracks the deadline for every new hire, performs [or assigns] the document review, and runs the retention log.
• Hiring managers: confirm start dates to [HR] as soon as offers are accepted, and never let anyone start work before the I-9 process is underway.
• Onboarding coordinator [if separate]: sends the new hire the Section 1 link/form and the USCIS list of acceptable documents before day one.
• [Name/role]: runs the [annual] internal I-9 audit and the purge of forms past their retention date.

3. The two federal clocks

Per USCIS, the employee completes Section 1 of Form I-9 by their first day of work for pay, and {{org.name}} completes the employer section — examining the employee's original documents — within 3 business days of the employee's start date. Both deadlines are tracked in [system] from the moment a start date is confirmed.

If an employee cannot present acceptable documents in time [beyond any receipt rules in the current USCIS instructions], escalate to [HR/role] before the deadline passes, not after — and never backdate: a late form honestly dated is a correctable problem, a falsified one is not.

4. Section 1 — the employee

1. 1Send the new hire Form I-9 [or the Section 1 link in [system]] with their offer packet, along with the current USCIS list of acceptable documents — so they can choose what to bring without anyone suggesting a document.
2. 2Confirm the employee has completed and signed Section 1 by their first day of work for pay: legal name, address, date of birth, and their attestation of status. The attestation is theirs alone — staff answer process questions but never advise which status box to check.
3. 3Check Section 1 for completeness the day it arrives — blank fields and missing signatures found on day one are fixed in minutes; found in an audit, they are findings.

5. Employer document review

1. 1Ask the employee to present original documents from the USCIS lists of acceptable documents. The choice is theirs, between two routes: one document proving both identity and authorization to work, or one proving identity plus one proving authorization. Never specify, suggest, or reject a valid choice.
2. 2Examine the originals with the employee physically present [or under any alternative procedure currently authorized by USCIS, where {{org.name}} is eligible — check the current rules].
3. 3Apply the reasonable standard: does the document appear genuine and relate to the person presenting it? You are not a forensic examiner — accept documents that reasonably appear genuine; if one does not, let the employee choose others from the lists.
4. 4Record the document details in the employer section exactly as the current instructions require, enter the first day of employment, and sign and date within 3 business days of the start date.
5. 5[If {{org.name}} retains document copies: retain them for everyone verified the same way, attached to the I-9, never selectively — and note that E-Verify has its own copy rules.]

6. Corrections and reverification

1. 1Correct errors properly: draw a single line through the wrong entry, write the correction, and initial and date it. Never use correction fluid, never obscure the original entry, and never backdate — employees correct Section 1, the employer corrects its own sections.
2. 2Track work-authorization expiration dates in [system] and reverify before expiry where current USCIS instructions require it — and not where they say not to; unnecessary reverification is a discrimination risk.
3. 3Run an internal audit [annually]: sample [or review all] I-9s for completeness, correct what can be corrected with dated annotations, and record the audit and fixes at [location] — a documented self-audit is the best posture before a government one.

7. Retention and storage

• Retain each I-9 for as long as current USCIS retention guidance requires — the rule combines hire and separation dates, so [name/role] logs a destruction date at offboarding rather than guessing later.
• Store I-9s separately from personnel files, in a dedicated [binder/electronic] system at [location], so an audit response exposes I-9s and nothing else.
• Electronic storage [if used] follows the current federal standards for electronic I-9 systems — confirm your vendor attests to them.
• Access is limited to [named roles], and forms past their retention date are destroyed on schedule and logged — keeping I-9s forever just enlarges the audit surface.

8. E-Verify, records, and review

E-Verify remains optional for most employers — required by some states and certain federal contracts — so requirements vary by state and locality. {{org.name}} [does / does not] use E-Verify: [if enrolled — create cases within the timeframe current E-Verify rules require, follow the case result procedures exactly, and take no adverse action on an interim case status]. E-Verify supplements the I-9; it never replaces it.

This procedure is reviewed [frequency, e.g. annually], whenever USCIS publishes a new form or instructions, and after any audit finding. Owner: [name/role]. Next review due: [date].