Form I-9 for Remote Employees: The Authorized Representative Process Explained

Completing Form I-9 for remote employees is one of the trickiest parts of hiring someone you'll never meet in person. Federal law still requires an employer to examine the new hire's identity and work-authorization documents within three business days — even when the employee lives in Fredericksburg and your office is in Ohio, or vice versa. The fix most small businesses use is an authorized representative: a person you designate to meet the employee, inspect the original documents, and complete Section 2 for you. This guide walks employers and new hires through the whole process, including the E-Verify video alternative.

Form I-9 basics: who does what, and when

Form I-9 has two main parts plus two supplements. The deadlines run from the employee's first day of employment for pay — not the offer date, and not the orientation date if that's unpaid.

Use a current edition. The current Form I-9 carries an edition date of 01/20/25 and an expiration date of 05/31/2027. USCIS also accepts the 08/01/23 edition that shows the 05/31/2027 expiration date. The older 08/01/23 version that expired 07/31/2026 should no longer be used. Download the form only from uscis.gov/i-9 so you always get a valid version.

Two ways to verify a remote employee

Under USCIS rules, the employer or its representative must generally review the employee's documents in the employee's physical presence. For a remote hire, that leaves two lawful paths:

How the authorized representative option works

USCIS defines an authorized representative as any person you designate, hire or contract with to complete, update or correct Section 2 (or Supplement B) on your behalf. Examples include personnel officers, foremen, agents and notaries public. You don't need a written contract. Three rules matter most:

1. The employer remains liable. USCIS states that you are liable for any violations "committed by the authorized representative acting on your behalf." Choose someone careful, and review the completed form when it comes back.
2. The employee can't be their own representative. An employee can't complete Section 2 for themselves or vouch for their own documents. That includes "just snap a photo and fill it in yourself."
3. A notary isn't acting as a notary. When a notary serves as an authorized representative, they follow the same steps as anyone else. They should not place a notary seal on Form I-9. The form is not notarized.

The person who examines the documents must be the same person who completes and signs the Section 2 certification. You can't have one person look at the documents and another sign.

The DHS alternative procedure for E-Verify employers

Since August 2023, employers that participate in E-Verify in good standing can examine documents remotely instead of in person. Good standing means you're enrolled in E-Verify for every hiring site that uses the procedure, you use E-Verify for new hires, and you follow the program's other rules. USCIS's remote-examination guidance still describes this option as available. The steps:

1. Collect copies. The employee sends copies (front and back, if two-sided) of the documents they choose.
2. Hold a live video call. The employee presents the same originals on camera. You confirm they reasonably appear genuine and relate to the person.
3. Keep the copies. Retain clear, legible copies with the Form I-9.
4. Check the box. Mark the alternative-procedure box in Section 2 on current editions of the form.
5. Create the E-Verify case. Do this no later than the third business day after the employee starts work for pay.

If you offer the alternative procedure at a hiring site, you must offer it consistently to all employees there. USCIS allows you to offer it only to remote hires while physically examining documents for on-site and hybrid workers, as long as that choice isn't discriminatory. E-Verify employers should also remember that any List B document must have a photo, and the employee must provide a Social Security number.

Acceptable documents: List A, or List B plus List C

The employee decides which acceptable documents to present. The employer must make the Lists of Acceptable Documents available, but cannot specify which ones the employee shows. Asking for "your passport" or rejecting a valid driver's license plus Social Security card can be a discrimination problem.

What to know about the lists

• Originals only. With in-person examination, photocopies aren't acceptable. The one exception is a certified copy of a birth certificate.
• Unrestricted Social Security cards only. A card that says "Not valid for employment" or "Valid for work only with DHS authorization" doesn't count for List C.
• Receipts are limited. A receipt for replacing a lost, stolen or damaged document is valid for 90 days, after which the employee shows the replacement. Receipts can't be used if the job will last less than three business days.
• Older card designs are still valid. Green cards and EADs issued in earlier designs remain acceptable until they expire.
• Recent list changes. The 01/20/25 edition revised the descriptions of two List B documents and renamed one Section 1 checkbox. USCIS has also issued several 2026 updates on Temporary Protected Status that affect certain EADs. If an employee presents a TPS-related EAD or an auto-extended card, check I-9 Central's current guidance before accepting it.

What the employer should send the representative

Most authorized-rep problems start with an incomplete packet. Before the appointment, email the representative and the employee:

• The current Form I-9 (01/20/25 edition, or the 08/01/23 edition expiring 05/31/2027), with Section 1 completed by the employee or ready for them to complete.
• The Form I-9 instructions and the Lists of Acceptable Documents. The employee must have access to these.
• The employee's first day of employment, which goes in Section 2.
• Your business name and address as they should appear in the Section 2 certification block.
• Whether you use E-Verify, so the representative knows a List B document must have a photo.
• Your copy policy. Should the representative copy the documents? If you copy for one employee, copy for all.
• Return instructions — how and by when the completed form should come back (secure upload, encrypted email or tracked mail).

Don't send the representative a list of which documents to accept. That's the employee's choice.

What the employee should bring to the appointment

If you're the new hire, here's how to make the meeting quick:

1. Finish Section 1 first. Complete and sign Section 1 before or at the start of the appointment, and no later than your first day of paid work. If someone helps you, they also complete Supplement A.
2. Bring original, unexpired documents. Bring either one List A document, or one List B and one List C document. A U.S. passport alone covers everything. So does a driver's license plus an unrestricted Social Security card.
3. Leave the photocopies at home. Pictures on your phone and photocopies don't count (except a certified birth certificate).
4. Check names. If your documents show different names (for example, after marriage), bring them anyway and mention it. The representative will record what each document shows.
5. Bring the employer's instructions and the form if they sent you a paper copy.

Retention and reverification

How long to keep Form I-9

Keep each employee's Form I-9 for three years after the date of hire, or one year after employment ends — whichever is later. Keep the form for the whole time the person works for you. You may store I-9s on paper or electronically, and many employers keep them apart from personnel files so they can produce them quickly in an inspection.

If you used the alternative procedure, the document copies must be kept with the form. If you copy documents under the in-person method, keep them with the form too.

Reverification (Supplement B)

When an employee's work authorization or document showing it expires — for example, a dated EAD — complete Supplement B no later than the expiration date. The employee may present any unexpired List A or List C document (or an acceptable receipt). An authorized representative can handle reverification for a remote employee the same way. Don't reverify U.S. citizens and noncitizen nationals, lawful permanent residents who presented a green card, or any List B identity document. USCIS suggests reminding employees about 90 days before expiration.

Common Form I-9 mistakes with remote hires

• Missing the three-day deadline because the representative wasn't arranged until after the start date. Book the appointment when the offer is accepted.
• Letting the employee "self-verify" by filling in Section 2 or emailing photos to HR without E-Verify and the alternative procedure.
• A notary stamping the form. Form I-9 isn't notarized, and the seal adds nothing.
• Specifying documents, such as "bring your passport," or rejecting a valid List B + C combination.
• Accepting copies or expired documents during an in-person exam.
• Leaving fields blank in Section 2: document title, issuing authority, number, expiration date, the first day of employment, or the representative's name and title.
• Using an expired form edition or an outdated electronic I-9 system.
• Skipping the alternative-procedure checkbox, or using video for some remote hires and in-person exams for others at the same site without a non-discriminatory reason.
• Reverifying people who shouldn't be reverified, such as green card holders.

Form I-9 is just one piece of onboarding. For withholding forms, Virginia new-hire reporting and payroll setup, see our guide to hiring your first employee in Virginia, or let our payroll services team handle it. If your new hire has other paperwork to sign, our notary services are in the same office. To set up an I-9 appointment, book online or call (540) 479-1500.

Written by the Timeless Tax & Accounting teamTimeless Tax & Accounting was founded in 2020 by Nagham Alobaidi and serves clients across Virginia and in other states, in English and Arabic. Reviewed for accuracy against IRS and Virginia Tax guidance as of October 2, 2026.

This page is general information, not tax, legal or financial advice for your specific situation. Tax rules change often — talk with a professional before acting.