1. Purpose and Scope
This Standard Operating Procedure defines how [Organisation Name] verifies identity and employment authorization. It covers completing, correcting, storing, and retaining Form I-9 for all US-based employees, including full-time, part-time, and temporary staff.
This procedure ensures we meet federal deadlines, apply anti-discrimination rules consistently, and keep audit-ready records across the organization.
Working through related paperwork at the same time? See also our Written Statement of Employment Particulars Template, Hiring Process Template and Performance Review & One-to-One Template (UK).
2. Roles and Responsibilities
- [HR / Designated Role]: Owns this procedure. Tracks compliance deadlines, conducts or oversees document review, maintains retention logs, and manages record disposition.
- Hiring Managers: Notify [HR / Designated Role] immediately when a candidate accepts an offer. Ensure new hires perform no paid work before starting the Form I-9 process.
- Onboarding Coordinator: Sends Section 1 and the official list of acceptable documents to new hires before their first day of work.
- [Auditing Lead / Role]: Conducts periodic internal audits of Form I-9 records and oversees the destruction of records past their required retention period.
3. Federal Deadlines
- Section 1: The employee must complete this no later than their first day of paid work.
- Section 2: The employer must complete this within three business days of the employee’s start date.
Track both deadlines in [System] once the employee’s start date is confirmed. If a new hire cannot present acceptable documentation within the required timeframe, escalate the issue to [HR / Designated Role] before the deadline expires. Never backdate a form.
4. Section 1 Completion Process
- Provide Form I-9 and the current list of acceptable documents with the offer packet. Give the candidate the full list of document options without suggesting specific items.
- Confirm the employee signed, dated, and completed Section 1 by their first day of paid work. Check for legal name, address, date of birth, and legal status attestation. Staff may answer procedural questions but cannot advise the employee on which status to select.
- Review Section 1 for completeness on the day it is submitted. Correct blank fields or missing signatures immediately.
5. Employer Document Review Process
- Ask the employee to present original, unexpired documents from the official list. They may present either one List A document (establishing both identity and work authorization) or a combination of one List B document (identity) and one List C document (work authorization). Never demand, specify, or reject valid documentation options.
- Inspect original documents with the employee physically present. Alternatively, use an authorized remote inspection procedure if [Organisation Name] meets federal eligibility criteria.
- Verify that documents reasonably appear genuine and relate to the individual presenting them. If a document does not reasonably appear genuine, allow the employee to select alternative documentation from the acceptable list.
- Record document details in Section 2, enter the start date, and sign and date the form within three business days of the start date.
- If [Organisation Name] retains document copies, apply this policy uniformly to all verified employees. Attach copies directly to the Form I-9 and follow system standards.
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6. Corrections and Reverification
- Correct errors on existing forms by drawing a single line through incorrect information, entering the correct data, and adding initials and the date. Never use correction fluid, obscure original entries, or backdate changes. Employees must make corrections to Section 1; the employer must correct Sections 2 and 3.
- Track work authorization expiration dates in [System]. Conduct reverification in Section 3 before authorization expires whenever federally required. Do not reverify identity documents, green cards, or documents that do not require reverification.
- Audit active and inactive Form I-9 records on a [Frequency, e.g., annual] basis using a sample or full review. Document all corrective actions with dated notes and log the audit results in [Location].
7. Retention and Storage
- Retain each Form I-9 for the duration federal guidelines require based on hire and termination dates. Calculate and log the exact destruction date during employee offboarding.
- Store Form I-9 records separately from standard personnel files in a dedicated [physical binder / electronic storage system] located at [Location / System].
- Ensure electronic storage systems comply with federal security, indexing, retrieval, and audit trail standards.
- Restrict file access to [Designated Roles]. Destroy records that reach the end of their mandatory retention period on schedule, and record the disposal in the destruction log.
8. E-Verify Requirements
- [Organisation Name] [uses / does not use] E-Verify to supplement Form I-9 procedures.
- When using E-Verify, submit cases within the required federal timeframe after completing Section 2.
- Follow official case result protocols exactly. Take no adverse action against an employee while a case remains in an interim status.
- E-Verify acts as a secondary check; it does not replace the requirement to complete and retain Form I-9.
9. Review and Governance
[Role] maintains this procedure and reviews it [Frequency, e.g., annually], upon the publication of revised federal forms or instructions, or following audit findings.
- Document Owner: [Role]
- Approval Date: [Date]
- Next Review Date: [Date]
FAQs on a form i-9 employment verification procedure
What is a form i-9 employment verification procedure?
A form i-9 employment verification procedure defines how your organisation verifies identity and employment authorization. It covers completing, correcting, storing, and retaining Form I-9 for all US-based employees, including full-time, part-time, and temporary staff.
Having it written down means the same rules apply to everyone, so managers are not making judgement calls case by case under pressure.
What does a form i-9 employment verification procedure include?
This template covers federal deadlines, section 1 completion process, employer document review process and corrections and reverification.
Every section is written to be filled in. The bracketed placeholders mark the decisions that are yours to make, such as timescales, approval owners and retention periods.
How to implement a form i-9 employment verification procedure with Whale
Copy this template into Whale and work through the bracketed placeholders so it reflects how your organisation actually operates.
Assign it to the teams it applies to so it sits where people work rather than in a shared drive, and set a review date so it gets revisited on schedule instead of quietly going out of date.
Use our templates to fast-track your documentation
Customize this template and 100s of others for free in Whale, the fastest way to get your team aligned.
