Short version. Use this I-9 reverification HR checklist for 2025 and 2026 to plan monthly sweeps, remote I-9 steps, and clean Section 3 timing.
It spells out what you do not reverify, what you must reverify, and how to keep work authorization tracking simple and on schedule for remote I-9 2025 and remote I-9 2026.
I-9 reverification HR checklist for 2025 and 2026: remote I-9 and work authorization tracking
Who/What you do not reverify
- U.S. citizens and nationals.
- Lawful permanent residents. Do not reverify, even if the green card shows an expiration date.
- List B identity-only documents, such as a driver’s license.
Who/What you must reverify
- Work authorization with an end date, for example, many EADs and some I-94-based statuses.
- Status or name updates that change the document presented for Section 2 or reverification.
- I-94 or I-797 end dates when these control ongoing authorization to work.
Tip: Some EAD categories get an automatic extension if the renewal is filed on time. Keep a quick reference and record the temporary end date your team will track against.
Your Q4 to Q1 calendar
Every Monday
- Pull a 90-day look-ahead list from your tracker. Tag green, yellow, red.
- Email managers of yellow and red employees with a two-line status and the next action.
On the 15th each month
- Run a document chase for reverifications due within 45 days.
- If you use an alternative remote I-9 procedure as an E-Verify employer, send one message with the photo upload and live video instructions to reduce back-and-forth.
Last business day each month
- Hold a 15-minute clean desk check with HR ops: missing receipts, pending renewals, travel holds, and any cases waiting on a manager.
Quarter start (Oct 1 and Jan 1)
- Refresh your companywide roster. Add new hires, remove departures, and confirm owners.
- Publish a one-page executive snapshot: counts due in 30, 60, 90 days, plus risk notes and cost exposure.
The 60–30–0 rhythm
60 days before expiration
- Confirm the status path with the employee and manager: extend, transfer, or wind down.
- If a filing is needed, start now and add a travel hold note.
30 days before
- Collect the renewal proof for reverification: receipt notice, updated I-94, or new EAD.
- Schedule the remote I-9 2025 or remote I-9 2026 video step if you use the DHS alternative procedure.
On or before expiration (Day 0)
- Complete Section 3 with acceptable evidence or pause work if proof is not available.
- Update the tracker, notify payroll and the manager, and clear any travel holds when done.
Remote I-9 2025–2026 quick guide
- Use the same procedure companywide. If you use an authorized alternative procedure, publish the exact steps and who can perform the live video check.
- Save legible copies of the front and back of documents when your policy requires it.
- Keep a fallback in-person path for locations or roles that cannot use remote steps.
Manager messages you can paste
Chase note at 45 days
“Your employee [Name] has work authorization expiring on [date]. We need renewal evidence by [date]. Please confirm travel plans and any role or location changes this month.”
Reverification appointment note
“We will complete I-9 reverification for [Name] on [date] using our remote process. Please make sure [Name] has the new document ready for upload and the video call.”
If proof is missing on Day 0
“We do not have valid work authorization on file for [Name] as of today. Work must pause until we receive acceptable evidence. We will review daily with you.”
Controls that prevent last-minute fire drills
- One intake for any status change, extension, or move.
- Travel hold rule when a renewal or visa stamping is in play.
- Weekly 10-minute sweep of the red list with Legal or your provider.
- Single owner per employee and a published escalation lane.
Pitfalls to avoid
- Waiting for the physical EAD when a timely filed renewal provides a temporary extension you can rely on for reverification.
- Re-doing I-9s for a legal name change. Update records, but do not redo Sections 1 and 2 unless required.
- Forgetting dependents whose travel or status shifts can affect plans.
- Using different rules for remote and in-person sites without a written reason.
One-page summary you can share internally
- What not to reverify
- What to reverify
- The 60–30–0 rhythm
- Monthly sweep dates
- Manager message templates
- Escalation contacts
Disclaimer: Content in this publication is not intended as legal advice, nor should it be relied on as such. For additional information on the issues discussed, consult a WayLit-affiliated attorney or another qualified professional.
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