Form I-9 Remote Document Examination: The DHS Alternative

Employers enrolled in E-Verify and in good standing can examine Form I-9 documents remotely under a DHS alternative procedure available since August 1, 2023. The employer reviews copies of the documents, holds a live video call where the employee presents the same originals, checks the alternative procedure box, keeps copies, and creates an E-Verify case.

Key takeaways

  • Only employers enrolled in E-Verify for every hiring site that uses the procedure can use it, and they must stay enrolled and in good standing while they use it.
  • The procedure has five required steps; skipping the copy retention step is one of the easiest ways to fail an audit.
  • Employees who are unable or unwilling to use the remote process must be allowed to present documents for physical examination.
  • You may limit the procedure to remote hires, but you must not choose who qualifies for a discriminatory reason.
  • The usual deadlines still apply: Section 2 within three business days of the hire and the E-Verify case by the third business day after the employee starts work for pay.

Who can use the remote I-9 alternative procedure?

DHS authorized the procedure in a Federal Register notice published July 25, 2023, under 8 CFR 274a.2, which lets the Secretary of Homeland Security authorize optional alternatives to physical document examination. The notice limits use to "qualified employers," meaning employers that participate in E-Verify and are in good standing. Good standing, in the notice's terms, includes being enrolled in E-Verify with respect to all hiring sites in the United States that use the alternative procedure.

That definition creates a practical trap for multi-site employers. A company may have enrolled only some locations in E-Verify years ago. If a non-enrolled location starts onboarding remote hires using video calls, those Forms I-9 were not completed under an authorized procedure. Before you roll the process out, pull a list of hiring sites from your E-Verify account and compare it with the locations in your HR system.

SituationCan you use the alternative procedure?
Enrolled in E-Verify for the hiring site, in good standingYes
Not enrolled in E-Verify at allNo; documents must be physically examined
Enrolled for some sites but not the site handling this hireNo, not for that site
Employee asks to present documents in personThe employer must allow physical examination
Reverification of an expiring work authorizationYes, but do not create a new E-Verify case for reverification

What are the steps for remote I-9 document examination?

The Federal Register notice lists five steps, performed within three business days of the employee's first day of employment:

  1. Examine copies. The employee sends copies of the documents, front and back if two-sided. You review them to confirm they reasonably appear to be genuine.
  2. Hold a live video interaction. The employee presents the same documents on a live call. You confirm they reasonably appear genuine and relate to the person on camera. A recorded video does not satisfy this step.
  3. Mark Form I-9. Check the box in Section 2 (or in the reverification section) indicating the alternative procedure was used.
  4. Retain copies. Keep a clear and legible copy of all documents presented, front and back if two-sided, with the Form I-9.
  5. Make copies available. If DHS or another federal agency audits or investigates, the copies must be produced.

Separately, E-Verify participants must create a case for all newly hired employees. The E-Verify User Manual says the case must be created no later than the third business day after the employee starts work for pay.

A practical live video script

  • Confirm the employee's name and that they are the person completing Section 1.
  • Ask them to hold each document close to the camera, front then back.
  • Ask them to tilt the document so you can see security features such as holograms.
  • Compare the photo on the document with the person on camera.
  • Compare the documents on camera with the copies received earlier.
  • Record the date of the video call and the name of the reviewer in your onboarding notes.

Can you offer remote examination to some employees and not others?

Yes, with limits. The notice allows an employer to offer the procedure only to remote hires while keeping physical examination for onsite or hybrid employees, provided the choice is not made for a discriminatory purpose. If you offer it to some employees at an E-Verify hiring site outside that remote-only approach, you must offer it consistently to all employees at that site.

The notice is explicit that employers must never decide who qualifies based on citizenship, immigration status or national origin. A policy that offers video verification to "employees with US passports" but requires in-person review for everyone else would fail. Write the eligibility rule in neutral terms tied to work location, and apply it the same way every time.

Also remember the opt-out. Employees who are unable or unwilling to submit documentation through the alternative procedure must be allowed to present documents for physical examination. Build that choice into your offer letter or onboarding portal so nobody feels pressured into a video call.

What are the most common remote I-9 mistakes?

MistakeWhy it mattersFix
No copies retainedRetaining clear copies is a mandatory step of the procedureMake document upload a required onboarding task
Alternative procedure box left blankThe form does not show which method was usedAdd the checkbox to your Section 2 review checklist
Recorded video instead of live callThe notice requires a live video interactionSchedule calls; do not accept uploads in place of the call
Site not enrolled in E-VerifyThe employer is not a qualified employer for that siteReconcile E-Verify hiring sites with HR locations quarterly
E-Verify case created late or not at allCases are due by the third business day after work for pay startsTrigger case creation from the same onboarding task
List B document without a photoE-Verify employers may only accept List B documents that contain a photoTrain reviewers on the E-Verify List B rule

For employees with unusual document combinations, such as students on practical training, review our F-1 student I-9 verification guide before the video call, so the reviewer knows which documents to expect.

How long do you keep remote I-9 records and copies?

Under 8 CFR 274a.2, employers must retain each Form I-9 for three years after the date of hire or one year after employment ends, whichever is later. The document copies made under the alternative procedure should be kept with the form for the same period, since they must be available during a federal audit or investigation.

A few practical points:

  • Store copies in the same system as the Form I-9 so purge rules apply to both together.
  • Restrict access, because the copies contain identity document images.
  • Calculate the purge date when employment ends, not at hire, because the formula depends on the termination date.
  • Keep I-9 files separate from general personnel files to make audits easier.

If your workforce spans several states, our article on multistate HR records retention explains how to set one retention schedule that meets the longest applicable rule. For remote hires, align the I-9 process with the location and work arrangement terms in your remote employee contracts, so the work site recorded in onboarding matches the one in the agreement.

Frequently Asked Questions

Can an authorized representative do the video call instead?

Employers can still use an authorized representative to physically examine documents in person, which is often the right answer for employers not enrolled in E-Verify. The alternative procedure itself is defined in terms of the qualified employer's examination, so if you delegate the video call to a vendor, confirm in writing that the vendor follows all five steps on your behalf and returns the copies to you.

Does the alternative procedure apply to reverification?

Yes. The Federal Register notice says the procedure can be used for reverification where applicable. Do not create a new E-Verify case when you complete reverification. Use the alternative procedure box in the reverification section, retain copies of the new documents, and set a reminder for the next expiration date if the new document also expires.

What if the documents look questionable on video?

The standard is the same as in person: documents must reasonably appear to be genuine and relate to the individual. If something looks wrong, you may ask the employee to present other acceptable documents of their choosing, but you cannot demand a specific document. Document your concern and treat every employee consistently to avoid discrimination claims.

Could we use the procedure for employees hired before August 2023?

Generally no. The notice says it applies from August 1, 2023. The exception was for employers enrolled in E-Verify that had remotely examined documents under the COVID-19 flexibilities between March 20, 2020 and July 31, 2023; those employers could use the procedure to satisfy the follow-up physical examination, with a deadline of August 30, 2023.

Next steps to set up remote I-9 verification

  1. Confirm every hiring site that will use remote examination is enrolled in E-Verify.
  2. Write a neutral eligibility rule (for example, all fully remote hires) and an opt-out for physical examination.
  3. Build the five steps into your onboarding workflow with required document uploads and a scheduled live call.
  4. Train every reviewer on the live video script and the List B photo rule.
  5. Run a quarterly self-audit of a sample of remote Forms I-9, checking the box, copies and E-Verify case dates.

Find more payroll and employment eligibility topics in our payroll and compliance guides. This article is general information, not legal advice; check current USCIS and E-Verify guidance before changing your process.

Last reviewed: October 2026.

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