On June 20, 2025, the U.S. Department of Homeland Security (DHS) issued updated guidance for employers following the revocation of certain Employment Authorization Documents (EADs), particularly for individuals under the CHNV (Cubans, Haitians, Nicaraguans, and Venezuelans) humanitarian parole program.
With ICE serving over 5,278 Notices of Inspection in 2025, non-compliance risks penalties of up to $2,789 per Form I-9 violation and $27,894 for knowingly employing unauthorized workers (ICE, 2025; HRlogics, 2025).
DHS’s Updated EAD Reverification Guidance
Following the U.S. Supreme Court’s May 30, 2025, decision to lift a federal injunction, DHS resumed terminating parole for CHNV program participants, revoking associated EADs. Employers must now take proactive steps to comply with the new guidelines:
- Status Change Report Replaces Case Alerts: DHS has discontinued E-Verify Case Alerts, directing employers to generate the Status Change Report in E-Verify to identify employees with revoked EADs. This report includes case numbers, A-numbers, and revocation dates.
- Prompt Reverification: Employers must reverify work authorization for affected employees using Form I-9, Supplement B within a “reasonable amount of time,” typically 10 days, as per ICE audit practices.
- Acceptable Documents: Employees must present unexpired List A or List C documents (not List B identity documents) to confirm work eligibility. Revoked EADs are invalid, even if unexpired on their face.
- No New E-Verify Cases: Reverification is completed solely via Form I-9, Supplement B, without initiating new E-Verify cases.
- Non-Discrimination Compliance: Employers must avoid discrimination based on national origin or immigration status, allowing employees to choose valid documents during reverification, per the Immigration and Nationality Act.
- Manual EAD Checks: Non-E-Verify employers can verify EAD validity (cards starting with “IOE”) on the USCIS website.
These changes, driven by legal developments in the CHNV litigation, require employers to stay vigilant to avoid costly penalties.
Challenges in EAD Reverification
The updated guidance introduces several compliance challenges:
- Increased Administrative Burden: Manually generating Status Change Reports replaces automated Case Alerts, adding workload for HR teams.
- Tight Deadlines: Completing reverifications within 10 days is critical to avoid fines, especially for organizations with large or remote workforces.
- Error Risks: Paper-based Form I-9 processes have a 76% error rate, increasing the likelihood of penalties during ICE audits (Buchalter Law Firm, 2024).
- Remote Verification Complexity: Verifying documents for remote employees requires DHS-compliant video verification, permitted through August 30, 2025.
How EMP Trust HR Simplifies Compliance
EMP Trust HR’s Electronic Form I-9 and E-Verify solutions, trusted by over 850 customers across 52+ countries, streamline EAD reverification and ensure compliance with DHS’s 2025 guidelines. Our platform offers:
- Automated E-Verify Integration: Seamlessly pulls Status Change Reports to identify revoked EADs, reducing manual effort and ensuring timely notifications.
- Error-Free Reverification: Built-in validation for Form I-9, Supplement B reduces errors by up to 90%, ensuring accurate documentation (Mitratech, 2024).
- Remote Verification Support: Mobile-friendly portals and DHS-compliant video verification simplify reverification for remote employees, meeting the August 30, 2025, deadline.
- Secure Audit Trails: Cloud-based storage with detailed logs cuts ICE audit preparation time by 50%, keeping records organized and accessible (EMP Trust HR Internal Data, 2025).
- Compliance Training Modules: Multilingual resources keep HR teams informed on DHS regulations, ensuring non-discriminatory practices and accurate processes.
Steps to Ensure Compliance with EMP Trust HR
- Access Status Change Reports: Use EMP Trust HR’s E-Verify integration to generate and monitor Status Change Reports for revoked EADs.
- Complete Reverification: Process Form I-9, Supplement B within 10 days using our platform’s real-time validation for error-free compliance.
- Support Employee Choice: Allow employees to select valid List A or List C documents, guided by our system to ensure compliance.
- Maintain Secure Records: Store all forms and audit trails in our encrypted cloud platform for quick retrieval during ICE inspections.
- Track Compliance Metrics: Use real-time analytics to monitor reverification progress and maintain audit readiness.
Call to Action
Stay ahead of DHS’s 2025 EAD reverification requirements and protect your business from ICE penalties. With EMP Trust HR’s Electronic Form I-9 and E-Verify solutions, serving over 850 global customers, you can simplify compliance and reduce risks effortlessly. Schedule a personalized demo to ensure audit-ready compliance.
