I-9 Reverification
I-9 reverification explained: when Supplement B is required, who never needs reverifying, how to complete it, and how staffing agencies keep track of the dates.September 25, 2026
4 min read
Onboarding
Written by the NextCrew team
Definition
I-9 reverification is the process of confirming that an employee whose work authorization has an expiration date is still authorized to work, before that date passes. The employer records it in Supplement B of Form I-9 (formerly Section 3), using a current document the employee chooses from List A or List C.
For a staffing agency, I-9 reverification is a date that has to be caught across the whole active pool. The agency is usually the employer that completes the Form I-9 for its Crew Members, so the agency, not the client, owns reverification. Miss the date and the Crew Member cannot keep working until it is done; reverify the wrong person and the agency can create a discrimination problem.
When is I-9 reverification required?
Reverify when the employee's employment authorization, or the List A or List C document that shows it, expires. Do it no later than the earlier of the authorization expiration date the employee entered in Section 1 or the expiration date of the document recorded in Section 2.
Who does not need I-9 reverification?
| Situation | Reverify? |
|---|---|
| U.S. citizens and noncitizen nationals | No |
| Lawful permanent residents who presented a Permanent Resident Card (green card) | No, even when the card expires |
| An expired List B identity document, such as a driver's license | No |
| Employment authorization with an expiration date (for example, an EAD) | Yes, before it expires |
Summary only. The USCIS Handbook for Employers (M-274) covers special cases, such as automatic extensions of some employment authorization documents.
How do you complete I-9 reverification?
- 1Track the date
Know each Crew Member's reverification date well ahead of time.
- 2Remind the employee early
Tell them what is needed and by when. They can present any acceptable List A or List C document.
- 3Let them choose the document
You cannot ask for a specific document, or the same kind they showed before.
- 4Examine and record
Complete Supplement B with the new document's details, sign and date it, and attach it to the original Form I-9.
- 5Keep it with the file
Retain it for as long as you retain the Form I-9.
What happens if an employee cannot be reverified in time?
An employee who cannot present acceptable evidence of continuing work authorization by the date cannot continue working. Handle it the same way for everyone, document what happened, and get legal advice before taking action, because treating people differently by citizenship or national origin during reverification can itself be a violation.
Where agencies get I-9 reverification wrong
- Reverifying green cards. A lawful permanent resident's expired card does not trigger reverification.
- Asking for a specific document. The employee chooses from List A or List C.
- Tracking dates in a spreadsheet nobody owns. Dates pass unnoticed across a large active pool.
- Letting the client handle it. If the agency completed the I-9, the agency owns reverification.
- Using E-Verify for reverification. E-Verify is not used to reverify; Supplement B is.
Bottom line: reverify only when work authorization expires, never for citizens or green-card holders, and let the employee choose the document. The hard part at scale is catching every date in time.
How NextCrew helps
NextCrew does not complete or validate Form I-9 and is not an I-9 compliance tool. It helps agencies keep track of the date:
- Onboarding packages. Packages sent at hire commonly include the I-9 along with W-4, direct deposit and consent forms.
- Dated tasks with reminders. A task on the Crew Member's record with a due date sends reminders automatically before the date, and tasks attached to Crew profiles flow into compliance tracking and reporting.
- Messages from the record. Remind the Crew Member by email, SMS or push, with the conversation stored on their profile.
See employee onboarding software.
Frequently asked questions
Related terms
- Primary source verification: confirming a license or certification with the body that issued it.
- Staffing agency license: the state registrations an agency itself needs.
- Co-employment: why the agency, as employer of record, owns employment paperwork.
- Redeployment: moving Crew Members to new assignments, where current authorization matters.
General information, not legal or immigration advice. Follow the current USCIS Handbook for Employers (M-274) and ask counsel about specific cases.