Remote Hiring Guide

Remote Employees and I-9 Verification: What Employers Need to Know

Hiring remote workers? Form I-9 still applies—but completing it gets more complicated. Learn how to verify employment eligibility when you can't meet your new hire in person.

Key Points for Remote I-9 Verification
I-9 is still required for all U.S. employees regardless of where they work
Original documents must be physically examined—no copies or scans
Authorized representatives can examine documents on your behalf
Same deadlines apply: Section 2 within 3 business days of start

The Challenge of Remote I-9 Verification

Form I-9, Employment Eligibility Verification, requires employers to physically examine original identity and work authorization documents in the employee's presence. This requirement was designed for traditional office environments—but today, millions of employees work remotely and may never visit a company office.

So how do you complete I-9 for someone you've never met in person? The answer involves understanding the "authorized representative" option and knowing your legal obligations.

Important: You Can't Skip I-9 for Remote Workers

Every employee who works in the United States must have a completed I-9, regardless of whether they're in-office, hybrid, or fully remote. The only exception is employees working entirely outside the U.S. The penalties for non-compliance are the same whether the employee works in your office or from their home 1,000 miles away.

The Solution: Authorized Representatives

Since you can't physically examine documents through a screen, the primary solution for remote I-9 verification is to designate an "authorized representative" to complete Section 2 on your behalf.

What Is an Authorized Representative?

An authorized representative is any person you designate to act on your behalf to complete Section 2 of Form I-9. This person must:

  • Be physically present with the employee
  • Examine the employee's original documents
  • Complete and sign Section 2 of the I-9
  • Return the completed form to you for your records

Who Can Be an Authorized Representative?

Almost anyone. The regulations don't require special qualifications. Common choices include:

  • • Notary public
  • • HR professional (at a PEO or staffing agency)
  • • Attorney
  • • Accountant
  • • Bank employee
  • • Public library staff
  • • UPS Store or similar business
  • • Family friend or neighbor

Note: The employee cannot act as their own authorized representative. Family members technically can serve as representatives, but using an unrelated third party provides better documentation in case of an audit.

Step-by-Step: Remote I-9 Process

1Send I-9 Section 1 to the Employee

Before or on the employee's first day, send them Form I-9 with instructions to complete Section 1. They can do this electronically or on paper.

Timeline: Section 1 must be completed no later than the first day of work for pay.

2Identify an Authorized Representative

Find someone in the employee's area who can verify documents. Options include:

  • Notary services: Many UPS Stores, banks, and shipping centers offer notary services
  • Virtual notary services: Some states allow remote notarization (but the I-9 still requires physical presence)
  • Agent network: Services that specialize in remote I-9 verification
  • Local contact: A professional contact, friend, or neighbor you trust

3Provide Instructions to the Representative

Send clear instructions to your authorized representative on how to complete Section 2:

  • • Employee must present original documents (not copies)
  • • Representative examines documents for authenticity
  • • Representative records document information in Section 2
  • • Representative signs and dates Section 2
  • • Include employer's business name and address in Section 2

4Conduct the Verification Meeting

The authorized representative meets with the employee in person, examines the original documents, completes Section 2, and signs the form. This must happen within 3 business days of the employee's first day of work.

5Receive and Store the Completed I-9

The representative returns the completed I-9 to you (electronically, by mail, or fax). Store it with your employee records. You must retain the form for 3 years from hire date OR 1 year after employment ends, whichever is later.

6E-Verify (If Applicable)

If you use E-Verify, submit the case within 3 business days of the employee's start date. E-Verify compares the I-9 information against government records to confirm work authorization.

Need paystubs for remote employees?

Generate professional paystubs regardless of where your team works.

Create Paystubs

Year-end tax forms

W-2s work the same for remote and on-site employees.

W-2 Generator

E-Verify and Alternative Procedures

Employers enrolled in E-Verify have access to alternative procedures that can simplify remote verification in certain circumstances:

E-Verify Alternative Procedure (Post-COVID)

DHS has implemented alternative procedures for E-Verify employers that allow document examination via live video interaction. However, specific requirements apply:

  • Must be enrolled in E-Verify
  • Live video interaction required (not pre-recorded)
  • Employee must transmit copies of documents
  • Must retain copies of documents with I-9
  • Physical examination must still occur within specific timeframe

Check Current Guidelines: E-Verify procedures evolve. Visit the USCIS website or consult with an immigration attorney to confirm the current alternative procedures available.

Not Using E-Verify?

If you're not enrolled in E-Verify, you must use the standard authorized representative method for remote employees. E-Verify enrollment is voluntary for most employers (though mandatory in some states and for federal contractors). Consider enrolling if you hire remote workers regularly—it provides additional options for document verification.

Common Remote Hiring Scenarios

Best Practices for Remote I-9 Compliance

Plan Ahead

Before extending an offer, identify how you'll complete I-9 verification. Don't wait until day 3 to scramble for a solution.

Build a Representative Network

If you hire remotely often, establish relationships with authorized representatives in common locations.

Document Everything

Keep records of who served as your authorized representative, when verification occurred, and any communications about the process.

Consider E-Verify

E-Verify provides additional verification tools and may offer more flexibility for remote document examination.

Don't Cut Corners

Never accept photocopies, skip the physical examination, or backdate forms. Penalties apply regardless of intent.

Train Your Team

Ensure HR staff and hiring managers understand remote I-9 requirements and have clear processes to follow.

Frequently Asked Questions

Remote employee onboarding checklist

Identify authorized representative in employee's location
Employee completes I-9 Section 1 by first day of work
Representative examines documents and completes Section 2 within 3 days
Employee fills out W-4 for tax withholding
Set up payroll and paystub generation
E-Verify case (if enrolled) within 3 business days