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Form I-9 & Employment Eligibility FAQs

I-9 completion, document rules, remote verification, and fixing the I-9 problems audits find most often.

Last updated: July 03, 2026 • 9 answers in this category

Form I-9: the rules that decide an audit

Controlling authority: USCIS Form I-9 and the Handbook for Employers (M-274). Document abuse is enforced separately by the DOJ Immigrant and Employee Rights Section, not only by ICE.

Form I-9: the rules that decide an audit U.S. Citizenship and Immigration Services, I-9 Central and the Handbook for Employers (M-274). Table by Faulkner HR Solutions.
RuleRequirementWhere employers go wrong
Section 1 timingNo later than the first day of employment, and not before the offer is acceptedCompleting it at interview stage is itself a violation.
Section 2 timingWithin three business days after the first day of employmentCounted from the first day of work, in business days. A Monday start means Thursday.
Who chooses the documentsThe employee, from the Lists of Acceptable DocumentsSpecifying, requesting extra, or rejecting valid documents is document abuse — enforced by the DOJ Immigrant and Employee Rights Section, separately from ICE.
UnexpiredDocuments must be unexpired when presentedThere is no general exception; the receipt rule is narrow and temporary.
ReverificationOnly when employment authorisation expiresYou never reverify a Permanent Resident Card or a U.S. passport. Doing so is discrimination.
RetentionThree years after the date of hire, or one year after termination, whichever is laterEmployers apply the earlier date and destroy files that were still required.
Copies of documentsOptional, but the practice must be consistent for everyoneCopying for some employees and not others is evidence of discrimination.

The Form I-9 clock

The Form I-9 clockFive points on the Form I-9 timeline from offer acceptance through retention and disposal, with the deadline attaching to each.1AFTER OFFERSection 1Employee completes it.Not before the offeris accepted.2DAY 1Section 1 dueNo later than thefirst day ofemployment.3+3 BUSINESS DAYSSection 2Monday start meansThursday deadline.Business days.4ON EXPIRYReverifyWork authorisation only.Never a permanentresident card.53 YRS / 1 YRRetainThree years after hireor one year aftertermination. Later wins.
Figure The Form I-9 clock. Two points cause most of the damage: Section 2 runs on business days from the first day of work, and the retention rule is a “whichever is later” test that employers routinely resolve the wrong way and destroy files early. U.S. Citizenship and Immigration Services, Form I-9 and retention and storage. Figure by Faulkner HR Solutions.
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Curated and reviewed by Dr. Thomas W. Faulkner, DBA, MBA, MSML, SPHR, LSSBB, principal consultant at Faulkner HR Solutions.