On August 11, 2026, DHS expanded the E-Verify Status Change Report to include certain invalidated Employment Authorization Documents — meaning an employee's EAD can look valid on paper while their underlying work authorization no longer is.
Why it matters: An employee can still physically hold an EAD that looks facially valid even after DHS has invalidated the underlying employment authorization. E-Verify employers now need a process to catch that gap.
Employment authorization compliance is becoming less about checking a document once and more about staying alert to changes in an employee's status over time.
The Status Change Report was introduced by DHS in 2025 to notify employers enrolled in E-Verify when certain employees' employment authorization had been revoked or otherwise changed. It became especially relevant following the termination of work authorization for groups such as CHNV parolees and individuals affected by changes to Temporary Protected Status (TPS).
Initially, the report primarily covered C11 EADs associated with certain parolees. As of August 11, 2026, DHS has expanded the report to cover additional EAD categories tied to asylum, adjustment-of-status, and TPS cases.
DHS may invalidate certain EADs based on changes to the underlying immigration application or status — without necessarily collecting the physical document.
| EAD Category | Generally Associated With |
|---|---|
| C08 | Asylum applicants |
| C09 | Adjustment-of-status applicants |
| A12 | Individuals granted Temporary Protected Status (TPS) |
| C19 | TPS applicants |
This means an employee may still physically possess an EAD that appears valid on its face, while DHS has determined that the underlying employment authorization is no longer valid. That distinction is critical for employers monitoring their E-Verify account.
DHS has stated that it may invalidate certain EADs based on changes to the underlying immigration application or status:
DHS does not necessarily collect the physical EAD when employment authorization changes, so an employee can continue to hold a document that looks facially valid even though the underlying authorization has been terminated or invalidated. The Status Change Report gives participating E-Verify employers another way to identify these changes.
Employers should not assume the printed expiration date on an EAD tells the entire story once a Status Change Report notification has been received. At the same time, employers should not draw conclusions from unrelated immigration enforcement activity.
An arrest, detention, release from custody, removal proceedings, or participation in an alternative-to-detention program does not automatically mean an individual's employment authorization has ended. Similarly, involvement in immigration proceedings does not, by itself, establish a loss of employment authorization.
Use information from the appropriate compliance process, not assumptions — and consult qualified immigration counsel when the situation is unclear.
“An EAD appearing on a Status Change Report requires the employer to follow the appropriate reverification process — it does not eliminate the employee's rights under the Form I-9 and anti-discrimination framework.”
Inconsistent treatment of employees in similar circumstances creates additional compliance and discrimination risk — which is why a documented, consistently applied process matters as much as the notification itself.
Establish clear ownership for actively monitoring your E-Verify account and reviewing Status Change Reports as they're generated.
A designated owner should check the report on a regular cadence, flag affected employees, and route each case into your reverification workflow without delay.
The employee should provide unexpired documentation from List A or List C of the Form I-9 Lists of Acceptable Documents.
The employer should complete Supplement B of Form I-9 to document the reverification, keeping a clear record of what was presented and when.
Employers should not dictate which specific document an employee must present when the employee has a choice among acceptable options.
Steering an employee toward one specific document — rather than letting them choose from the acceptable list — can create unnecessary discrimination exposure.
An existing employee who appears on the Status Change Report should not be treated as a new hire for E-Verify purposes.
The Status Change Report triggers a reverification workflow, not a new E-Verify case — the two processes are separate and shouldn't be conflated.
List B documents establish identity and are not subject to reverification. The focus stays on establishing continuing employment authorization.
Centralize reverification, Supplement B, and audit trail in one workflow.
Explore Electronic Form I-9Reverifying identity documents unnecessarily can create confusion for the employee and adds risk without addressing the actual issue: whether employment authorization is still current.
Current DHS guidance does not set a specific universal timeframe for reverification after a Status Change Report notification — which makes an internal, documented process even more important.
Assign clear ownership of the Status Change Report and affected employee records.
Define who reaches out to the employee and how the request is documented.
Set a reasonable, consistently applied timeframe for providing documentation.
Define the point at which HR or legal counsel gets involved.
Track follow-ups, decisions, and outcomes for every affected employee.
Apply the same process to similarly situated employees, every time.
Define next steps if acceptable documentation isn't provided in time.
Not just a policy — a policy applied the same way, every time, for every employee.
Participating employers can receive Status Change Report notifications for revoked or invalidated EADs — giving visibility that's otherwise hard to get.
That visibility comes with a responsibility to monitor reports and respond appropriately, every time.
Employers that don't participate in E-Verify generally do not receive Status Change Reports.
Where E-Verify isn't mandatory, this visibility gap may be another factor when deciding whether to participate.
Organizations with large or geographically dispersed workforces may find monitoring, communicating, and documenting reverification across hundreds or thousands of employees difficult to manage manually.
High-volume, distributed workforces with frequent turnover.
Project-based crews across multiple job sites and locations.
Seasonal labor with time-sensitive verification needs.
Regulated environments where compliance gaps carry added risk.
This is where a structured, digital Form I-9 process helps organizations create a consistent workflow instead of relying on manual tracking across locations.
When employment authorization rules change, the challenge isn't just knowing a change happened — it's making sure your organization can respond consistently, document what happened, and keep Form I-9 records audit-ready.
EMPTrust HR's electronic Form I-9 and E-Verify solutions help organizations centralize employment verification workflows, track Form I-9 activity, manage reverification processes, and maintain electronic records and audit trails — reducing reliance on manual tracking across locations.
Talk to EMPTrust HR about centralizing E-Verify monitoring, Form I-9 reverification, and audit-ready documentation.
