Form I-9 basics for recruiters: what must be completed and when

Form I-9 basics for recruiters come down to four questions. Who fills out which section? Which documents count? When is each piece due? How long is the form kept? This page covers the I-9 employment eligibility verification basics using USCIS guidance, then translates them into a recruiting workflow. It is general information, not legal advice.

What Form I-9 is and who it covers

USCIS describes Form I-9 as the form used to verify the identity and employment authorization of people hired for employment in the United States. Coverage is broad: "All U.S. employers must properly complete Form I-9 for every individual they hire for employment in the United States. This includes citizens and aliens." No new hire is skipped because of citizenship.

Employers must also "Have a completed Form I-9 on file for each person on their payroll who is required to complete the form." For high-volume hiring, that means every hire in every batch, at every location.

Who completes Section 1 and Section 2

The form is a shared job. In USCIS's words: "Both employees and employers (or authorized representatives of the employer) must complete the form." The new hire handles Section 1. The employer handles Section 2. Two supplements apply only in specific cases.

Section 2: examining documents

Section 2 is more than data entry. "The employer must examine these documents to determine whether they reasonably appear to be genuine and relate to the employee, then record the document information on the employee’s Form I-9." Some employers can examine documents remotely, but only under a specific procedure: "Certain employers who choose to remotely examine the employee’s documentation under a DHS-authorized alternative procedure must check the box in Section 2 to indicate they did so."

Deadlines and timing

The USCIS form page covers some timing directly and points to the Handbook for Employers (M-274) for the rest. Treat the handbook as the authority on exact windows.

• Initial completion: timing for Section 1 and Section 2 is set out in the M-274 handbook, which has a dedicated chapter on completing Section 1. USCIS says "Employers should check this online version of the handbook periodically for updates." Confirm the current windows before you build an onboarding schedule.
• Reverification: Supplement B applies "when an employee requires reverification of their employment authorization or, in some cases, employment authorization document, or if the employer chooses to document a rehire."
• Retention: there is a defined minimum period, covered below.
• Form edition: USCIS lists which editions are currently valid on the Form I-9 page, and employers using an electronic I-9 must keep their systems on the current edition.

The practical takeaway for recruiters: start document collection right after offer acceptance. The person completing Section 2 should never be waiting on a new hire who did not know what to bring.

Acceptable documents

The new hire presents documents as evidence of identity and employment authorization. The employer supplies the official list. USCIS: "Page 2 contains the Lists of Acceptable Documents that employers must provide to employees, either as a hard copy or as a hyperlink to this form. Employers do not need to retain this page with an employee’s Form I-9." Employers must also "ensure that employees have access to the Instructions for completing Form I-9, by providing them either a hard copy or a hyperlink."

Do not write your own version of the list. Link to the official one. The M-274 handbook also contains a section on unlawful discrimination and penalties for prohibited practices. Read it before you write any candidate-facing message about documents.

If you collect eligibility documents online during onboarding, new hires upload what your process requires from any device, and the files sit with their onboarding record. The platform collects and stores the documents. It does not decide which documents are acceptable, and it does not replace your team's review, attestation, or E-Verify submission.

Retention and inspection

Completed forms stay with the employer. USCIS says to "Retain and store Form I-9 for three years after the date of hire, or for one year after employment is terminated, whichever is later" and to "Make their forms available for inspection if requested by authorized U.S. government officials from the Department of Homeland Security, Department of Labor, or Department of Justice." The form is not sent anywhere: "Do not file Form I-9 with U.S. Citizenship and Immigration Services (USCIS) or U.S. Immigrations and Customs Enforcement (ICE)."

Keep Supplement A when a preparer or translator helped, and Supplement B when reverification or a documented rehire occurs. The Lists of Acceptable Documents page does not need to be kept.

What it means for a recruiting workflow

1. 1 Flag the I-9 at offer Tell every new hire the form is required and share the official Lists of Acceptable Documents and instructions by hyperlink.
2. 2 Collect documents inside onboarding Run document upload in the same flow as the digital W-4 and other new-hire tax forms, so it is not a separate task the new hire forgets.
3. 3 Hand off to a named Section 2 reviewer Decide who examines documents and completes Section 2 at each location. Use your roles and permissions setup to think through who should see stored identity documents.
4. 4 Track who is outstanding Check document-collection status per new hire instead of chasing inboxes, especially during a bulk hiring push.
5. 5 Keep E-Verify separate If your business uses E-Verify, that step is handled by your team. Document collection does not submit anything for you.

Hi [First name], congratulations on your offer for [Role] at [Location]. Every new hire completes Form I-9, Employment Eligibility Verification. You will fill out Section 1 and provide documents from the official Lists of Acceptable Documents: [link to USCIS list]. The form instructions are here: [link]. You can upload your documents in your onboarding checklist: [onboarding link]. [Reviewer name] will complete the employer section with you. Questions? Reply here.

Common mistakes

• Treating an upload as a completed I-9. Collecting files is not the same as examining them and completing Section 2.
• Skipping the form for citizens. It applies to every hire.
• Sending a homemade document list instead of the official Lists of Acceptable Documents.
• Typing or e-signing the fillable PDF. It must be printed and signed by hand.
• Forgetting Supplement A when a preparer or translator helped with Section 1.
• Mailing completed forms to USCIS or ICE.
• Purging forms too early. Calculate both retention dates and keep the later one.
• Using the Spanish-language form outside Puerto Rico. USCIS says "Only employers located in Puerto Rico may complete the Spanish-language version of Form I-9 instead of the English-language version." Others may use it only as a translation tool.

The I-9 is one piece of employee onboarding. For related rules earlier in the funnel, see EEO basics for recruiters and how background check disclosure and consent work.