I-9 reverification: 3 checks before expiry

Key takeaways

• Build your tracking list from Section 1.
• Use the earlier expiration date when planning warnings.
• Record date comparisons and unresolved differences.
• Name an owner and a backup.

Hourly schedules change fast, and a worker's paperwork can slip out of view between shifts. Work authorization is one more date to track, and it is easy to miss until it is close. The Indeed onboarding guide says that in the United States, new hires may be required to fill out paperwork like Form I-9, Form W-4 (or W-9 for a contractor), and other state and local tax forms.

This post covers one part of that paperwork: what to check when a worker's employment authorization is set to expire. The three checks below come from U.S. Citizenship and Immigration Services (USCIS) guidance on Form I-9. Read the linked pages for the full steps, because a short post cannot cover every case. This post covers only the federal USCIS pages it links to. If a state or local rule applies to your workers, check that source separately.

A quick word on terms. Reverification is the step where a worker shows continued authorization to work. USCIS guidance says a worker is asked to present a List A or List C document to show continued employment authorization for reverification purposes. Knowing that term before you start makes the rest of the process easier to follow.

The post moves in order: first the list, then the warning, then the paper match. After the three checks, it covers talking with workers, keeping records, naming an owner, rehires, and common questions.

Check 1: Mark every worker whose Section 1 shows an expiration date

Check whether your employees indicated in Section 1 that their employment authorization will expire. (USCIS, Completing Section 1)

Start with the forms you already keep. Go through them one at a time and mark each worker whose Section 1 says that their employment authorization will expire. Do not rely on memory alone. A worker who always shows up may still have a date coming up that nobody has written down, and a list built from the files is easier to trust than one built from what you recall.

Keep the list short and useful. For each marked worker, record:

• The worker's name and job title
• The shifts they usually work
• The date their employment authorization is set to expire
• The date you plan to send the advance warning
• The date you last compared Section 1 with Section 2 (see Check 3)

Sort the list by the earliest date so the nearest deadline is at the top. A spreadsheet works well for this, and so does a printed page on a clipboard, as long as one person owns it and updates it when something changes. Ownership matters more than the tool. If three managers each keep their own copy, the copies will drift apart.

Review the list on a set schedule. A monthly review is a reasonable start for a small team. A weekly review makes more sense if your staff changes often or if several workers have dates in the same season. Pick a schedule, put it on the calendar, and stick to it. A list that nobody opens does not help anyone.

Bring the list into your scheduling routine too. When you plan the next schedule period, look at the list first. A worker whose date falls near the end of that period should be on your radar before the shifts are posted, not after. For a separate review before posting shifts, see the guide to schedule change approval.

Clean the list against your current roster once a month. Take off anyone who has left, and add anyone new who has an expiration date marked in their Section 1. Adding a new hire to the list at onboarding is the easiest time to do it, because the form is already in front of you. Keep this task alongside your other hiring steps.

Check 2: Plan the suggested 90-day advance warning

USCIS suggests giving employees at least 90 days advance warning to present evidence of continued employment authorization by the earlier expiration date of their authorization or documentation. Its guidance describes List A or List C documents and an acceptable alternative. (USCIS, Completing Supplement B)

The phrase "whichever is sooner" matters. A worker can have one date for employment authorization and another date for a document. The warning concerns the earlier of the two, so check both dates in the file before you set the warning date. If you look at only one, you may plan around the later date and miss the earlier one.

The two USCIS pages use the same 90-day figure with different verbs. The Supplement B page says "suggest." The Section 1 page says that you may remind workers at least 90 days before the expiration date that they will need to present a List A or List C document to show continued employment authorization for reverification purposes. Read both before you write your own process.

When you set a warning date, count backward from the earlier expiration date and make sure the notice goes out on or before the 90-day mark.

Illustrative example: Set the warning date

Suppose the earlier expiration date is 90 days away. Put the warning on today's calendar as its own reminder, separate from the expiration date itself. Record when you send it, then compare the authorization and document dates and note any difference for the person who owns the files.

Write the warning in plain words, and use the same terms USCIS uses so the worker knows what to bring. Check the linked guidance for acceptable evidence of continued employment authorization. Give a copy in writing. Keep a copy of what you sent and note the date. If your process includes written confirmation, ask the worker to sign it when you hand over the notice.

Use standard wording for the notice. This means you do not have to rewrite the wording under time pressure. A simple version might read: "Your Section 1 shows that your employment authorization will expire on [date]. Please plan to present evidence of continued employment authorization on [earlier of the two dates], following the linked USCIS guidance. Reply to confirm you received this note." Adjust the wording with whoever handles your I-9 files.

Plan around busy weeks. If an expiration falls during a season when your schedule is full, send the warning earlier. If a worker is hard to reach during a rush, give the message more time to get through.

If a worker does not respond to the notice, do not let the date pass in silence. Follow up through the same channel you used, write down each attempt with its date, and bring the file to the person who owns it. A missed reply is a reason to ask a question, not a reason to guess what the worker plans to do.

Check 3: Compare the Section 1 and Section 2 dates

Check whether the expiration date for employment authorization your employee provided in Section 1 matches the expiration date of the List A or List C document they presented for Section 2, Employer Review and Attestation. (USCIS, Completing Section 1)

This check is easy to skip when the form looks complete. USCIS notes that the two dates may not match: "The employment authorization expiration date provided by your employee in Section 1 may not match the document expiration date recorded under List A or List C in Section 2." (USCIS, Completing Supplement B)

Compare the two dates side by side. Pull the file, find the date in Section 1 and the date of the List A or List C document in Section 2, and check one against the other. Write down the date you compared, your initials, and what you found. A short note on the file is enough. If the dates differ, do not guess which one is right. Bring the difference to whoever manages your I-9 files and read the linked USCIS pages.

Make it a routine, not a one-time task. Run the comparison when a worker shows you a new document, before you file it, and again when your list shows a date is coming up. A first pass through older files may take longer than you expect, so schedule time for it instead of squeezing it between shifts.

Tie the check to the tracking list. Add a column for the comparison to the list from Check 1, so one review covers the expiration date, the warning date, and the match. If the list shows a worker whose dates have not been compared, put that name at the top of your next review.

Talk with each worker early, in private, and in plain words

Early notice is the point of the warning step. A conversation gives the worker room to ask questions before the deadline gets close. Start with the same facts you put in writing: the date on Section 1, the document types the guidance names, and the date by which the document is needed.

Pick a quiet time to talk, not the moment a worker is clocking in. Give them a short written copy of the notice to keep, so the details are not left to memory.

Keep the tone steady. Some workers will be relaxed about the notice, and others may be worried. Either way, the message should be the same: here is the date, here is the document, and here is who to contact with questions. Avoid guessing what a worker's paperwork means for their future on the schedule. Stick to the facts on the form and the guidance.

Do not use the conversation to ask for documents the guidance does not name. Follow the USCIS pages when explaining acceptable evidence.

If a worker has a question you cannot answer, say so, and point them to the person who owns the files. Write down the question and the answer so both sides work from the same facts later.

Record what date was checked, who checked it, and what they found

The record does not need to be long. A short entry for each check is enough, as long as the entries look the same for every worker.

For the warning, note the date sent, how it was delivered, and the expiration date you used. Delivery could be on paper, by email, or in person. For the match, note the Section 1 date, the Section 2 date, and whether the two matched.

Store the record with the file it describes, so the record and the form stay together. When someone asks what you did and when, the answer should be in one place.

Name one owner for the list and one backup

Ownership is what keeps the three checks working. The owner updates the list, sends or approves the warnings, and makes sure each comparison is noted. The backup should know where the list lives and how the notice wording works, so the process does not stop during a vacation or a sick day. Write both names on the list itself so the next person knows who to ask.

Check the earlier form's completion date for rehires

If you rehire your employee within 3 years of the date that a previous Form I-9 was completed, you may either complete a new Form I-9 for your employee or complete Supplement B of the previously completed Form I-9. (USCIS, Completing Supplement B)

This matters when a worker leaves your schedule and comes back. Before you choose between the two options, find the date the previous Form I-9 was completed. The 3-year window in the guidance is tied to that date, so the date on the old form is the one to check. Keep the old file where you can find it, so that date is easy to read when the worker returns.

Add a returning worker to your tracking list as soon as they are back on the schedule. If the rehire brings a new expiration date, run the three checks again on the new paperwork. Treat the return as a fresh start on the list, not a continuation of the old row.

Start today with the workers on your list

Read the linked USCIS pages in full before you adopt any step here. Treat this post as a summary that points you to the source, not as a replacement for it.

Today, open your current files and start the tracking list with workers whose Section 1 shows an expiration date. Add the warning dates and comparison results, then put the next review on the calendar.

Common questions

Must the Section 1 and Section 2 dates match?

The dates may differ, according to USCIS. Record the difference and bring it to whoever manages your I-9 files rather than guessing how to resolve it.

Is the 90-day warning described as mandatory?

USCIS describes the advance warning as a suggestion. Use that distinction when writing your process, and read the linked guidance for the document presentation deadline.

Which date starts the rehire window?

The previous Form I-9's completion date starts the 3-year window. Check that date before choosing between a new form and Supplement B.