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I-9 Compliance & Reverification Checklist

Provided by Catapult HR: stay compliant with Form I-9 requirements for every employee.

Section 1: Employee Information (Day 1)

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Employee must complete Section 1 no later than the first day of employment
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All fields must be completed — N/A is acceptable for non-applicable fields
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Preparer/translator must complete the certification block if employee received assistance
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Do not require specific documents — employees choose which acceptable documents to present
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Retain only the I-9 form, not copies of documents (unless you copy for ALL employees consistently)

Section 2: Employer Verification (Within 3 Business Days)

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Examine original, unexpired documents from List A, or one each from List B and List C
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Documents must reasonably appear genuine and relate to the person presenting them
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Record document title, issuing authority, number, and expiration date
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Sign and date Section 2 — must be completed within 3 business days of the start date
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Do not accept receipts as permanent documents (receipts are temporary, valid for 90 days)

Section 3: Reverification & Rehires

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Reverification required when: An employee’s List A or List C document expires
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Do NOT reverify U.S. passports, permanent resident cards, or List B documents
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Rehires within 3 years: Complete Section 3 on the existing I-9 or start a new form
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Rehires after 3 years: Complete an entirely new I-9
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Set calendar reminders 90 days before document expiration dates to initiate reverification

Common I-9 Errors to Avoid

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Asking for specific documents or more documents than required (document abuse/discrimination)
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Accepting expired documents for Section 2 (except for auto-extensions like TPS or EAD renewals)
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Backdating or leaving sections blank
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Failing to reverify when List A or List C documents expire
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Using outdated I-9 form versions (check USCIS.gov for current edition date)
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Not completing I-9s for remote employees (authorized representatives may complete Section 2)

Retention Schedule

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Retain I-9 for: 3 years from date of hire OR 1 year from date of termination — whichever is later
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Store I-9 forms separately from personnel files for easier access during audits
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Purge expired I-9s on a regular schedule to reduce audit exposure
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Maintain a tracking spreadsheet with hire date, term date, and calculated purge date
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Electronic I-9 storage is acceptable if system meets DHS audit trail and retrieval requirements

Need expert help implementing these practices? Catapult’s HR team is here for you.

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