How to Update I-9s Completed Remotely

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Employers that began conducting virtual employment eligibility verifications during the pandemic should begin physical inspections of completed I-9 forms as soon as possible in anticipation of the Aug. 30 deadline.


U.S. Immigration and Customs Enforcement (ICE) announced that the pandemic-era flexibility extended to the Form I-9 process is coming to an end on July 31, followed by a 30-day grace period to comply with physical Form I-9 document inspection requirements. This means employers that were conducting the I-9 process virtually over the last three-plus years will be required to conduct a physical inspection of original documents related to those prior remote I-9 completions by Aug. 30.


Having an Action Plan


First, employers will need to identify all the I-9 forms requiring updates. The completed ‘COVID’ I-9s need to be tracked from the start. The method of verification depends upon how your company stores I-9s—paper or electronically—and how you organize your system.


Here is an action plan for updating I-9’s completed during COVID:


  • Communicating with the entire workforce, outlining timing for compliance, and setting repercussions for not cooperating.
  • Deciding whether to perform the physical inspection of documents at the worksite or use an offsite third-party authorized representative to complete in-person inspections.
  • Training employees on conducting the physical document inspections and how to update I-9 forms. Ensure they are aware of the nuanced rules surrounding documents not found on the List of Acceptable Documents and automatic extensions of employment authorization documents. It’s also important to remember that employees can present their choice of eligible identity and work authorization documents when updating the forms—they do not need to present the same documents they initially presented.


The virtually completed I-9s should have been annotated in the Additional Information field with “COVID-19” as the reason for the delayed in-person inspection. This must be updated by annotating ‘documents physically examined’ with the accurate date and the name of the person who conducted the review in Section 2 of the I-9.


How you update your I-9 forms will depend on whether you use paper I-9s or an electronic I-9 system. Each electronic I-9 vendor would offer a specific workflow to update COVID I-9s. Companies using electronic I-9s should work with their vendor to understand how to identify remote COVID I-9s in the system, confirm a workflow exists to update these remote COVID I-9s with a physical inspection and ensure the system tracks the completion of updates to remote COVID I-9s.

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