Remote I-9 Verification: The Alternative Procedure Explained

You’ve hired someone four states away who starts Monday, and nobody from your company will be in the room. Remote I-9 verification lets you check their documents over live video, but only if you’re enrolled in E-Verify and in good standing. Otherwise someone must examine them in person, though that can be a representative you choose near the new hire.

Is remote I-9 verification allowed?

Short answer: Remote I-9 verification is allowed if you participate in E-Verify in good standing and follow the Department of Homeland Security’s (DHS) alternative procedure. If you don’t use E-Verify, the documents must still be examined in person, but you can designate an authorized representative near the employee to do it.

The legal basis is a DHS final rule published on July 25, 2023 (88 FR 47990) and effective August 1, 2023. It lets the Secretary of Homeland Security authorize alternatives to physical examination. A notice published the same day (88 FR 47749) set out the procedure itself, often called Alternative 1.

The notice says the procedure “does not expire,” although DHS can amend or cancel it and would announce that in the Federal Register. As of October 2026 we found no Federal Register document changing it, and USCIS’s remote examination page (last reviewed September 26, 2025) still describes the same four steps.

Don’t confuse it with the COVID-19 flexibilities. Those ended on July 31, 2023, and employers who weren’t in E-Verify had to physically examine those remotely reviewed documents by August 30, 2023.

Who qualifies for the I-9 alternative procedure?

Short answer: The Department of Homeland Security’s (DHS) alternative procedure is open only to employers enrolled in E-Verify at every hiring site that uses it. They must follow all E-Verify rules, including creating a case for each new hire, and stay in good standing the whole time they use it.

That’s DHS’s own definition of “good standing” in the 2023 notice. A few more conditions come with it:

• Training. Enrollment includes an E-Verify tutorial with fraud awareness and anti-discrimination training. USCIS says existing users can retake it any time.
• Consistency. If you offer the procedure at a hiring site, you must offer it to everyone hired there. You may limit it to fully remote hires and keep in-person checks for onsite and hybrid staff, as long as that choice isn’t made for a discriminatory purpose.
• The employee’s choice. An employee who can’t or won’t use video must be allowed to present documents for physical examination instead.
• Extra copies. You must keep clear copies of every document examined this way, front and back.

Should you enroll in E-Verify just for remote I-9s?

Short answer: Enrolling in E-Verify just for remote I-9s pays off only if you hire remote staff often. E-Verify is free, but enrolling commits you to its rules for every new hire at each enrolled site, not only the remote ones, so it’s far more than one video call.

The E-Verify user manual lists the rules you sign up for:

• Create a case for every new hire at an enrolled site, no later than the third business day after they start work for pay.
• Never use it to pre-screen applicants; a case comes only after the job offer is accepted and Form I-9 is done.
• Don’t run cases on people hired before you enrolled (some federal contractors are the exception).
• Display the E-Verify participation and Right to Work notices in English and Spanish, including for people hired to work remotely.
• Protect the personal data you collect.

There’s also E-Verify+, a free option that combines Form I-9 and E-Verify into one online process where the employee enters their own information and uploads document images. As of October 2026 it’s open only to Employer Access accounts with an active program administrator, not to Web Services users or E-Verify Employer Agents. Remote hires still need a live video interaction.

Our take: If you hire remote staff several times a year, enrolling in E-Verify is usually worth it for the video option alone. If you make one remote hire every year or two, a trained authorized representative near the new hire is often less work than taking on E-Verify’s rules for every future hire.

How to do a remote I-9, step by step

Here’s the sequence for a qualified employer, using the current Form I-9. Each step comes from the Form I-9 instructions, the 2023 DHS notice or USCIS guidance.

1. Send Section 1 after the offer is accepted. The employee must complete and sign Section 1 no later than their first day of work, and can’t do it before accepting the offer. Give them the form instructions and the Lists of Acceptable Documents, and don’t tell them which documents to bring.
2. Receive copies of the documents they choose. That’s one List A document, or one from List B plus one from List C, or an acceptable receipt. Ask for the front and back of anything two-sided.
3. Examine the copies. Check that each one reasonably appears to be genuine.
4. Hold a live video call. The employee shows the same original documents on camera, and you confirm they reasonably appear genuine and relate to the person on screen. Ask them to tilt each card at a few angles; the E-Verify fraud awareness training covers checking documents that way.
5. Complete Section 2. Enter the document details and the first day of employment, then tick the box that reads “Check here if you used an alternative procedure authorized by DHS to examine documents.” The person who examined the documents signs the certification.
6. Create the E-Verify case. Do it no later than the third business day after the employee starts work for pay.
7. File the copies with the I-9. Keep clear, legible copies of everything you examined. Keep the form itself for three years after the date of hire or one year after employment ends, whichever is later.

The whole process fits inside a short scheduled call, provided the copies arrive before it. E-Verify doesn’t charge for any of this; if you hire an outside I-9 vendor to run the calls, its pricing is between you and the vendor.

Tip: Book the video call before the start date and put it in the offer email. Steps 2 to 5 must all happen within three business days of the first day of work, and a missed call on day three leaves you no room to recover.

If you’re still finding the person to onboard, our remote staffing recruiters source and screen U.S. candidates; the I-9 itself stays with you as the employer.

What are the remote I-9 deadlines?

Short answer: For a remote I-9, Section 1 is due by the employee’s first day of work and Section 2 within three business days after that first day, according to USCIS’s Form I-9 instructions. The E-Verify user manual adds the E-Verify case, due by the third business day after they start work for pay.

The Form I-9 instructions give the example: if the employee starts on a Monday, Section 2 is due by that Thursday. Note that the clock starts on the first day of paid work, not the offer date.

What if you’re not an E-Verify employer?

Short answer: An employer that isn’t in E-Verify, or an authorized representative it picks, must examine the original documents in the employee’s physical presence. Almost anyone can be that representative, but the employer stays liable for what they do.

USCIS’s Handbook for Employers, section 2.0 says you may “designate, hire, or contract with any person you choose” and gives examples such as personnel officers, foremen, notaries public and agents. The rules for that person:

• Not the employee. Employees can’t act as authorized representatives for their own Form I-9.
• Same duties as you. They examine the originals in person, complete Section 2 and sign it. The same person who examined the documents completes the certification block.
• A notary isn’t notarizing. A notary acting as your representative should not put a notary seal on Form I-9.
• Your liability doesn’t move. The Form I-9 instructions say employers are liable for violations committed by anyone acting on their behalf.

In practice your options are a manager or colleague who lives nearby, a local notary who agrees to do it, or an I-9 vendor with a network of in-person agents. USCIS doesn’t bar relatives, but we’d avoid them: you’re answerable for their errors, and a family member is the hardest person to treat as an independent reviewer.

Send your representative a one-page brief with the deadline, the Lists of Acceptable Documents and a reminder not to ask for specific documents. Then check the finished Section 2 the day you receive it, while there’s still time to fix a gap.

Which Form I-9 edition should you use in October 2026?

Short answer: In October 2026, use the Form I-9 edition dated 01/20/25, which shows an expiration date of 05/31/2027. USCIS says the 08/01/23 edition marked with a 05/31/2027 expiration is also still acceptable; the 08/01/23 version that expired on 07/31/2026 is not.

According to the USCIS Form I-9 page (last updated June 3, 2026), the edition date is printed at the bottom of each page and the expiration date at the top. Employers using electronic I-9 systems had to update to the version expiring 05/31/2027 by July 31, 2026.

The 01/20/25 edition made only small changes, which USCIS announced on April 2, 2025: the fourth Section 1 checkbox now reads “An alien authorized to work,” two List B descriptions were revised, and the instructions gained statutory language and a new privacy notice. E-Verify updated its matching attestation on April 3, 2025.

Where you mark the alternative procedure depends on the edition:

• 01/20/25 or 08/01/23: tick the box in Section 2, or in Supplement B for a rehire or reverification.
• 10/21/2019: this edition is obsolete for new hires, but older forms completed on it show “Alternative Procedure” written in the Additional Information field.

What changed for Form I-9 and E-Verify in 2025 and 2026?

Short answer: The remote I-9 alternative procedure itself didn’t change in 2025 or 2026. What changed around it: a new Form I-9 edition, the end of automatic extensions for many renewed work permits (Employment Authorization Documents), an expanded E-Verify Status Change Report and a purge of old E-Verify records.

• Automatic EAD extensions ended for new renewals. A DHS interim final rule (90 FR 48799) took effect on October 30, 2025. Employees who file to renew an Employment Authorization Document (EAD) on or after that date no longer get the automatic extension of up to 540 days, and their receipt notice can’t be used alone or with an expired EAD as proof of work authorization. Extensions granted before October 30, 2025, or by law or Federal Register notice (such as some TPS extensions) still count. Comments closed on December 1, 2025; as of October 2026 we found no final rule replacing it.
• USCIS revised the Handbook. On July 7, 2026, USCIS revised sections 5.0 to 5.3 of the M-274 on automatic extensions, saying that in most cases recent developments “have reduced or eliminated” the extension periods for TPS-based EADs.
• The Status Change Report grew. Since August 11, 2026, E-Verify’s report of cases whose EAD was later invalidated covers categories A12, C08, C09 and C19 as well as C11 parolees. If an employee appears on it, reverify with Supplement B, let them choose any List A or List C document, and don’t create a new case.
• Old records are being deleted. Under an October 1, 2026 notice, E-Verify employers have until January 8, 2027 to download cases last updated on or before December 31, 2016 (a program administrator runs the Historical Records Report); USCIS will dispose of them on January 11, 2027.

Watch out: An expired EAD plus a renewal receipt used to be a routine combination. For renewals filed on or after October 30, 2025, it no longer proves work authorization, so check the receipt date before you accept it, and ask an immigration attorney about any case that doesn’t fit neatly.

What are common remote I-9 mistakes?

Short answer: Common remote I-9 mistakes include using video without being an E-Verify employer in good standing, forgetting the alternative-procedure checkbox, keeping no document copies and asking the new hire for a specific document. Under 8 CFR 274a.10, with DHS’s January 2025 inflation adjustment, failing the verification rules can cost $288 to $2,861 per person as of October 2026.

These are the errors we’d check for first in any remote onboarding process:

1. Using video without being in E-Verify, or at a hiring site that isn’t enrolled. Without good standing, a video review doesn’t count as examining the documents.
2. Forgetting the checkbox in Section 2, or in Supplement B for a reverification.
3. Keeping no copies. Under the alternative procedure, front-and-back copies are required for every employee you verified this way.
4. Photos only. Copies alone aren’t enough; DHS requires a live video interaction with the same documents.
5. Asking for a specific document, such as “send us your passport.” The form’s anti-discrimination notice says employees choose which acceptable documents to present.
6. Offering video to some people and not others at the same site without a neutral reason such as remote versus onsite work, or refusing an in-person check when an employee asks for one.
7. Running E-Verify too early, before the offer is accepted and Form I-9 is complete.
8. Letting the employee act as their own representative, or having a notary stamp the form.

Paperwork mistakes have a price. Under 8 CFR 274a.10, as of October 2026 the civil penalty for failing to meet the verification requirements is $288 to $2,861 for each person, for violations after November 2, 2015 (DHS’s January 2025 inflation adjustment; we found no 2026 adjustment). The regulation tells officials to weigh business size, good faith, seriousness, whether the person was unauthorized and any history of violations.

What to do this week

1. Decide your route. If you’re in E-Verify and in good standing, write down that you offer the alternative procedure to all remote hires. If you aren’t, name your authorized representative options before the next offer goes out.
2. Check your form. Make sure your paper stock or software shows Edition 01/20/25 (or 08/01/23) with an expiration date of 05/31/2027.
3. Build the video step into onboarding. Add the document request and the call booking to your offer email, with the three-business-day deadline stated plainly.
4. Review EAD holders. Flag any employee relying on a renewal receipt dated on or after October 30, 2025, and any name on the Status Change Report.
5. Download old E-Verify records before January 8, 2027, if your account goes back that far.

If you’re also working out payroll, taxes and registrations for the new hire, see our guide on how to hire remote employees in another state. This guide is a practical explainer, not legal advice: for a document you can’t place, a reverification or an audit notice, talk to an immigration attorney. We recruit and screen, but we don’t sponsor visas or file immigration paperwork. You can see everything we cover on our HR and staffing services page.