Imagine this: ICE has ramped up workplace raids again, targeting farms, restaurants, and hotels in major cities like Los Angeles and Washington, D.C. Their goal? At least 3,000 arrests per day. And these aren’t random — they’re part of a coordinated effort focused on employer compliance just as much as undocumented workers.
Pair that with civil fines reaching over $28,000 for a single Form I-9 mistake, and suddenly, a missing reverification isn’t just a paperwork issue — it’s a financial and legal risk.
If you employ staff who submit documents that expire and require reverification, you cannot afford to ignore this.
Let’s walk through exactly what you need to know to stay compliant and protect your business.
What Is Form I-9 and Why Does Reverification Matter?
Form I-9 is a federal requirement for every U.S. employer. It verifies that a new hire is legally authorized to work in the United States. But here’s the critical detail: some documents provided to complete Form I-9 are only temporary.
When those documents expire, you must reverify the employee’s work authorization before the expiration date.
But not every employee needs to be reverified. Reverification is required only when temporary documents are used. If an employee presented a U.S. passport or an unexpired green card, you’re typically in the clear.
Which Documents Require Reverification?
Form I-9 includes three key lists of documents:
- List A – Proves both identity and employment authorization
- List B – Proves identity only
- List C – Proves employment authorization only
Any documents from List A or List C that have expiration dates and do not indicate permanent status will need to be reverified.
Examples include:
- A foreign passport with a temporary I-551 stamp
- An expired green card with a USCIS receipt notice
- An Employment Authorization Document (EAD, Form I-766)
Reminder: U.S. citizens and lawful permanent residents with unexpired green cards generally do not need reverification.
How to Reverify Form I-9 Correctly
When it’s time to reverify, follow these steps carefully:
- Request new documentation from the employee that proves continued authorization to work. This can be any valid List A or List C document, even if it’s different from the original.
- Use Supplement B of the August 1, 2023, version of Form I-9.
- Enter the employee’s name and update it if there has been a legal name change.
- Complete a new section of Supplement B for each reverification event.
- Note future updates in the “Additional Information” field if needed.
- Sign, date, and attach the completed Supplement B to the employee’s original Form I-9.
Pro Tip: Set a Reverification Reminder System
Staying on top of expiration dates is crucial. A best practice is to set calendar alerts 90 days in advance of any known document expiration.
Let employees know (in writing) that updated documents will be required. While not legally required, giving advance notice is both professional and practical, and can prevent employment gaps due to expired work authorization.
Employees may sometimes provide a receipt for a replacement document, but this only buys a short window. Most receipts are valid for 90 days, after which you must update the I-9 with the new document.
Compliance Now Can Save You Thousands Later
Reverification might seem like a small administrative task, but the stakes are high. One mistake can lead to five-figure fines or even trigger a full audit.
The good news? With a reliable tracking system and a clear understanding of how to complete Supplement B, you can stay compliant and avoid costly penalties.
If you’re unsure about acceptable documents or need help setting up a reverification reminder system, we’re here to help.
📞 Call us at 310-534-5577
📧 Email: contact@abandp.com
Final Thoughts
Keeping your I-9s compliant isn’t just a legal obligation — it’s a smart business move that protects you, your team, and your bottom line.
If this post helped clarify the reverification process, please share it with others and leave a review. Have a question you’d love to see answered next? Drop us a message at media@abandp.com.
And if you’d like to support the podcast, you’ll find the link in the show notes.
Until next time — stay smart, stay compliant, and enjoy growing your business!
