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.
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 PaystubsE-Verify and Alternative Procedures
Employers enrolled in E-Verify have access to alternative procedures that can simplify remote verification in certain circumstances:
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
Related Resources
Explore more paystub solutions for your specific needs
Learn about I-9 requirements when hiring handymen or property managers.
Step-by-step guide to completing W-2 forms for employees.
Step-by-step guide to completing W-2 forms for employees.
Create professional paystubs for remote employees.
Generate year-end W-2 forms for your workforce.
Create W-4 forms for employee tax withholding setup.