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The I-9 Process – From Start to Finish

It pays to be I-9 compliant.

Inversely, poor I-9 compliance can cost loads. For wasted time, hefty fines, and even in public perception.

From $375 to $16,000 for each incomplete or inaccurate form. Repeat offenders often receive penalties at the high end.

Unable to produce Form I-9 in time for an audit? Expect to pay anywhere from $110 to $1,100 per violation.

ICE reported that in FY 2018, companies had to pay more than $10.2 million in judicial fines, forfeitures, and restitutions and that it levied a similar amount in civil fines.

We didn’t make that up.

Even worse, this can tarnish your company reputation and brand. One that you built up over years and years, decades even.

What a PR nightmare to lose that in a moment.

That can happen if U.S. Immigrations and Customs Enforcements (ICE) comes knocking.


The last thing you want is to spend time with ICE being audited.

There’s too much at stake.


Yet, the I-9 process can be tricky for many employers.

  • You must follow several steps correctly
  • There’s not much time to do this to meet I-9 requirements
  • Even more difficult if you’re a large company, on-boarding new employees across many locations

But don’t panic.

We wrote this piece for you. To help you complete the I-9 forms- completely, accurately, and on time.


Complete the I-9 Form: Easy as 1, 2 ,3.

Now that it’s clear, there is a high price to pay for not being I-9 compliant, let’s learn how to get and stay compliant.

There’s not a lot of information for completing a Form I-9. However, there are some complexities.

Again, not to worry.

Follow these steps to become knowledgeable and feel confident when hiring and verifying your employees.


Complete Section I: Capture Employee Information

For Section 1, it’s the responsibility of the employee to enter their information. It’s on you to ensure it’s complete and accurate.


Have the employee complete section 1 between the day they accept and the day they start.


An employee must provide their:

Full legal name

  • If they have more than one first and/or last names, include both
  • If they have one name, use the Last Name field. Then, enter “Unknown’ in First Name field.
  • Include any hyphen between their hyphenated name
  • State their middle name, if they have one

Other names, if they have any (like maiden name)

And all the other fields. Like address, date of birth, citizenship status, and more.

Optional fields include Social Security number*, email *, and telephone number (* = required if you’re using E-Verify).

Here’s a picture to help.

I-9 Full legal name

More information about Section 1…

Does the employee have a preparer or translator helping out?

If so…

  • The employee still must sign the form
  • The helper must state their name, address, date of certification and sign the form, too
  • If more than one helper, use the supplement section for each helper
  • Each helper must complete, sign and date a separate certification area
  • The employee must check the appropriate box, based on if a helper was used

Here, another picture for you.

I-9 Employee Signature


It’s simple.

Make sure the employee and any helpers completed everything as explained above.


  • Note when the employee’s employment authorization will expire
  • Remind the employee to present List A or List C 90 days before the expiration date
  • Employees must present these documents on or before their employment authorization expires
  • Use the documents to re-verify their continued employment authorization
  • The expiration dates given by the employee may not match with List A or C. Use the earlier dates to re-verify the employee.


Complete Section II: Review Employee Documents

Section 2 is about verifying the employee’s: 1) identity; and 2) work authorization.



You must complete and sign Section 2 of Form I-9, Employment Eligibility Verification, within 3 business days from when the employee starts work.



Employees must present unexpired, original documentation proving their identity and employment authorization.

They can present one document from List A or, one document from both List B and List C.



You or (an authorized representative) must complete Section 2:

  • Enter the employee’s last name, first name, middle initial and citizenship/immigration number. Use the information from Section 1.
  • Make sure all documentation is original and acceptable from this list
  • Physically examine the documents, to make sure they are genuine (if not, allow them to present something else from the acceptable list above)
  • Enter the document title, issuing authority, number(s) and expiration date (if any)
  • Enter the start date for the employee
  • Enter the first and last name, date, signature and title of the person completing Section 2
  • Enter the employer business name and address (for multiple addresses, use the one where the Form I-9 is completed)
  • Sign and date
  • Return the documentation to your employee

I-9 Section 2

Complete Section III: Reverify and Rehire

Did something change for the employee? If so, section 3 is for updating this information.

You MUST complete Section 3 when your employee’s employment authorization or documentation of authorization has expired (aka “reverification”).

You MAY complete Section 3 when your employee is rehired within 3 years or, they changed their legal name.

Note: When completing Section 3, you must also match the last, first, and middle name fields with Section 1 and Section 2.



Do you have an employee whose work authorization (or documentation) expired?

If so, you must reverify them to ensure they are still authorized to work.

How do you determine this?

  • Look in Section 1 for when their employment authorization expires
  • Look in Section 2 for when their authorization documents expire

If they don’t match, use the earlier date to determine when to reverify them.


No need to reverify if…

  • They are a U.S. citizen and noncitizen national
  • They are a lawful permanent resident who presented a Form I-551, Permanent Resident, or Alien Registration Receipt card for Section 2
  • They used List B documents


To complete Section 3, you must…

  • Physically examine the documents, to make sure they are genuine (if not, allow them to present something else from the acceptable list of documents)
  • Record the document title, number, and expiration date, if any
  • Sign and date the section

Note: Did you previously complete Section 3? Or, is the version of the form you used for a previous verification no longer valid? Then complete Section 3 of a new Form I-9. Use the most current version and attach it to the previously completed Form I-9.



Ready to rehire an employee? Is it within 3 years from completing the last Form I-9?

If so, you may…

  • Complete a new Form I-9 for your employee, or…
  • Complete Section 3 of the previous Form I-9

Here’s how.


To complete section 3 for rehires, you must…

  • Make sure the original Form I-9 pertains to your employee
  • Review the original Form I-9 to make sure your employee is still authorized to work

Is the employee still authorized to work? And, is the authorization documentation still valid (unexpired)?

If so, then enter the date of the rehire in Section 3.


But if not:

  • Have the employee present an unexpired List A or List C document
  • Do not reverify their List B (identity) document
  • Enter the document information and date of rehire in Section 3
  • Complete Section 3 on the current Form I-9 if it’s different from a previous version
  • Sign and date the section


About dates for Section 3:

  • For rehiring an employee, enter in block A their rehire date (this can be a future date)
  • For reverifying an employee, enter in block C the new expiration date of the work authorization document
  • Sign and date your attestation

I-9 Section 3

Change of name or identity

You are not required to update Section 3 of the Form I-9 when your employee changes their legal name.

Employees are not required to prove this to you, either.

However, it’s a good idea. Just to maintain current and correct information. You want to explain yourself as much as possible if ICE starts snooping around.


Now, what if an employee does change their identity? Like name, birth date, or SSN?

They’ll probably let you know.

So, you should:

  • Complete a new Form I-9
  • Enter the original hire date in Section 2
  • Attach the new Form I-9 to the old Form I-9
  • Re-examine the work authorization and documents as explained above
  • If it’s different, then complete Section 3 of the previous (or current) Form I-9

There you go. Completing your Form I-9, from start to finish.

We made it easier to understand than ICE does. But you can always go here.

Automate your I-9 verification process

Do less manually. Use (and lose) less paper. Reduce risk. Sleep better.

With CIC Plus you can

  • Coordinate I-9 verification wherever your employees live and work
  • Be compliant, at all times, with the latest regulations
  • Show and share the verification process with administrators
  • Record everything electronically, to survive and thrive an audit