How to Complete the I-9 for Remote Workers

Completing Form I-9 (I-9) for remote employees can feel more complex than in-person onboarding. However, it's increasingly becoming an HR necessity. ADP research found that 31% of the workforce consists of cross-metropolitan employees who work in a different city than their employers.

With the right process, employers can meet government requirements and avoid onboarding delays as they complete I-9s for remote employees.

What is an I-9?

Employers use an I-9 to verify a new hire's identity and work authorization for employment in the United States. All employers (or authorized representatives of the employer) are required to complete an I-9 for each employee hired after November 6, 1986.

At the time of hire, employers need to ensure each employee properly completes the I-9 form. As part of the process, new hires fill out Section 1 and present appropriate documents to confirm their identity and employment eligibility. Employers must then review those documents to determine whether they appear genuine and relate to the employee and record the document information in Section 2.

The table below outlines the basics of Form I-9, which is broken out into two sections and two supplements. The form also includes a list of acceptable documents that establish both identity and employment authorization.

Section name	Section overview	Completion deadline
Section 1	Employee must complete and attest that they are authorized to work in the U.S.	The employee's first day of work for pay
Section 2	Employee presents identity and work authorization documents. Employer physically examines original documents, records the information, and attests that the documents appear genuine and the employee is authorized to work. Documents must be unexpired. See "alternative procedure" below for remote verification options.	Within 3 business days
Supplement A	Any person who helps the employee complete an I-9 must complete this supplement.	When Section 1 is completed
Supplement B	Used for reverification when employment authorization expires, rehires within 3 years, and recording legal name changes.	No later than the date employment authorization expires

How to complete I-9 for remote employees

The process of completing the I-9 for remote employees can be different. Typically, for the I-9, employers must examine an employee's original documentation (not copies) in the employee's physical presence. Without a face-to-face review, employers need a clear, repeatable process to verify documents accurately and on time. Breaking the process into defined steps helps reduce errors and keep onboarding moving across distributed teams.

Step 1: Employee completes Section 1 of Form I-9

Employees must complete Section 1 of the I-9 no later than their first day of employment. This includes providing personal information and attesting to their authorization to work in the United States. Employers should provide the I-9 instructions for completing Section 1 and confirm that employees complete all required fields to avoid delays.

Step 2: Employer completes Section 2 (I-9 verification for remote employees)

Within three business days of the employee's start date, employers must review the employee's documents from the Form I-9 list necessary to verify identity and employment authorization for Section 2. Employers could designate an authorized representative, such as a notary, attorney or other agent, to physically review documents on their behalf. State law may restrict who can complete the I-9 on the employer's behalf. The employer remains responsible for ensuring the form is completed accurately and on time.

Employers also have the option to follow an "alternative procedure" to the in-person physical document examination method, provided they meet specific requirements. To qualify, employers must be enrolled in E-Verify and be considered in good standing. Qualified employers following the alternative procedure must take the following steps:

Examine copies (front and back) of the I-9 documents to ensure they reasonably appear genuine;
Conduct a live video interaction with the employee presenting the document(s) to ensure that the documentation reasonably appears to be genuine and related to the employee. The employee must first transmit a copy of the document(s) to the employer (per Step 1 above) and then present the same document(s) during the live video interaction;
Check the box on the I-9 indicating the alternative procedure was used; and
Retain clear, legible copies of all documents (front and back).

Step 3: Reverification and ongoing compliance (if applicable)

Supplement B of the I-9 is used for reverification and rehires when an employee's work authorization expires and for legal name changes. Not all employees will require this step, but employers should have a process in place to track when reverification is needed.

For both in-person and remote employees, this requires tracking reverification deadlines and coordinating the collection and review of updated documents. In general, the same workflows used for initial I-9 verification can be applied here.

Ways to help ensure remote I-9 compliance

Employers can help ensure that I-9 verification for remote employees is managed compliantly in a few ways.

Authorized representatives. Employers should establish a policy defining who may serve as an authorized representative. Because employers are liable for any violations committed by their representatives, select individuals with I-9 experience. Note that state laws may restrict who can complete the I-9 on an employer's behalf.

Reviews. Employers should implement a review process to identify common issues, such as incorrect document selection, missing document information or incomplete fields. Establishing a consistent review step can help improve accuracy, particularly when onboarding employees across multiple locations.

Document storage. According to federal regulations, employers must retain Form I-9 for three years after the date of hire or one year after employment ends, whichever is later.

Forms should be stored securely and remain available for inspection by authorized government officials, including representatives from the Department of Homeland Security (DHS), the Department of Justice and the U.S. Department of Labor. Employers should not mail Form I-9 to U.S. Citizenship and Immigration Services (USCIS) or ICE.

For additional guidance on how to complete the I-9 for remote employees, employers can refer to the Handbook for Employers M-274 provided by the USCIS.

Next steps

Completing the I-9 verification process efficiently helps set a positive tone for new hires. That's especially important for remote workers, who are 1.3 times more likely to feel insecure about their jobs than in-person or hybrid employees, according to ADP research. With clear processes and communication, employers can support both compliance and a stronger start to the working relationship.

Learn about employee onboarding best practices. Download our guide, Hiring 101: Guidebook for Growing Businesses.

^{This article was originally published as an "ADP HR Tip of the Week" which is a communication created for ADP's small business clients.}