Confirm your organization participates in E-Verify in good standing at the hiring site where the remote employee will work — only E-Verify-enrolled employers may use the DHS alternative procedure.
Instruct the employee to complete and sign Form I-9 Section 1 no later than their first day of employment; employees may not complete Section 1 before accepting a job offer.
Request that the employee transmit legible copies (front and back for two-sided documents) of their chosen List A or List B plus List C documents to the employer or authorized representative.
Conduct a live video interaction with the employee to examine the documents, confirming they reasonably appear genuine and relate to the individual presenting them.
Complete Section 2 within three business days of the employee's first day of employment; indicate on the form that the alternative procedure was used as required by USCIS guidelines.
Retain the document copies as required — employers using the alternative procedure must retain copies of documents examined remotely.
Known gotchas
The alternative procedure is only available at E-Verify-enrolled hiring sites; using it at a non-enrolled site does not create a statutory excuse and may constitute a verification violation.
Form I-9 has an expiration date — employers must update their electronic I-9 systems to use the version with the current expiration date no later than July 31, 2026.
Using an authorized representative (such as a notary or third-party vendor) to complete Section 2 does not transfer employer liability — the employer remains responsible for any errors or omissions.
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