What is Remote I‑9 Verification and How to Do It Right

If you’re in Human Resources (HR), then you know that onboarding a new hire isn’t just about extending an offer, sending out welcome emails and scheduling IT setups, it’s also about compliance. When it comes to federal hiring regulations, Form I-9 verification sits high on the priority list. But now, with today’s increasingly hybrid and remote work models, one question comes up now more than ever before:  

Can Form I-9 verification be done remotely? 

The answer is yes, but under certain conditions. Let’s discuss what that really means for HR managing I-9 verification for remote employees, how to stay compliant, and how to avoid common pitfalls along the way. 

Here’s three key takeaways you’ll learn in this article: 

1. What is remote I-9 verification and how does it work? 
2. How HR can help remain compliant throughout the process. 
3. Common issues to be aware of and HR best practices.  

What Is Remote I-9 Verification? 

Let’s review the basics for a bit of context. Form I-9 is a U.S. Citizenship and Immigration Services (USCIS) form that verifies the identity and employment authorization of individuals hired for employment in the United States. Every new employee hired onto a company’s payroll, regardless of citizenship status, must complete this form. Employers are then required to physically inspect the employee’s identification documents to confirm their validity. 

Traditionally, the term "physically" meant just that: in person, with original documents in hand. But then COVID-19 happened. In response to lockdowns and remote work, the Department of Homeland Security (DHS) introduced temporary flexibilities in 2020 to allow remote I-9 verification. Employers were allowed to review documents virtually over video calls or even email if certain criteria were met. There was an underlying caveat that once the lock down was lifted that employers would meet in person with those employees remotely verified to review documents in person per the standard process, which created a backlog for employers.   

Now here’s the big shift: As of 2023, DHS has made a version of remote verification a “permanent” option for certain employers. If your organization is enrolled in E-Verify and meets other conditions discussed later in this article, you can now use remote I-9 verification on an ongoing basis. That’s a game-changer for hiring remote talent. 

How Remote I-9 Verification Works 

So, how does I-9 verification remote actually work now? It’s still a two-step process, and the basics haven’t changed. Here’s the details: 

Section 1: Completed by Employee 

Your new hire must complete Section 1 of Form I-9 on or before their first day of employment. Whether you’re onboarding them in-person or remotely, this part remains unchanged. 

Here’s where digital tools come in: Employers can use an electronic I-9 system to collect and store Section 1 information. These systems often allow for electronic signatures, date stamps, and automated prompts that make it easier for employees to submit everything on time. 

Section 2: Completed by Employer or Authorized Representative 

Here’s where I-9 remote verification becomes especially relevant. 

Under DHS’s updated guidelines, employers enrolled in E-Verify can verify Section 2 virtually. That means you can inspect identity and work authorization documents via video conferencing tools like Zoom, Microsoft Teams, or Google Meets as long as you meet certain compliance standards. 

Here are the key requirements: 

1. Live video interaction: You must conduct a real-time video call to review the employee’s documents. Viewing a scanned image or a picture by itself doesn’t cut it. 
2. Clear, legible copies of documents: You must obtain and retain clear copies of the documents used for verification. 
3. Detailed audit trail: Your process must include logs of who verified what, when, and how, ideally with timestamps and user data if using an HRIS. 
4. Compliance with DHS criteria: You must indicate on the Form I-9  that you’re using the alternative procedure for remote verification. 

Bottom line is that I-9 verification for remote employees is possible, but it must be handled the right way. Also, remember that time completion timelines are non-negotiable. 

Common Risks and Pitfalls 

While the new flexibility is great, remote I-9 verification isn’t without its challenges. Here are some of the most common mistakes HR teams make and some specific tips on how to avoid them: 

1. Using Untrained Representatives: It’s tempting to ask a friend, family member, or local notary to act as an authorized I-9 representative for remote employees. But many of these individuals don’t understand I-9 requirements and mistakes here can cost you. 
   
   For example, a notary might affix a seal to the form, which is not required (and actually discouraged). Worse, friends or family might miss critical document details, record too many documents or complete the form incorrectly. 
   
   Tip: If you must use a third party, provide step-by-step instructions, and ideally, use a trained I-9 agent or authorized vendor. 
2. Poor Documentation of the Remote Process: If you don’t document how you performed remote verification, you leave yourself exposed during an I-9 audit. Every remote I-9 should include: 
   • A note stating it was completed via video 
   • The name of the verifier 
   • Date and time of the video call 
   • Copy of documents reviewed 
   
   Tip: Keep detailed notes or use an electronic system that auto-generates audit trails. 
3. Insecure Document Storage: Employee documents often contain sensitive information. Storing them in personal email, unsecured drives, or shared folders without encryption poses a data privacy risk. 
   
   Tip: Use a secure HRIS or document management system with role-based access and encryption. 
4. Autofill Errors from HRIS: Some HR platforms autofill I-9 forms with outdated or incorrect data. USCIS stated that Section 1 and Section 2 of Form I-9 may not be pre-populated except for the employer name and address in section 2.  
5. Risk of Civil Penalties: Mistakes in I-9s can lead to civil fines—even if they were unintentional. Paperwork violations can be anywhere from $288 to $2861.  
   
   Tip: Conduct internal audits annually to catch and correct errors before an external audit does. 

Remote I-9 Best Practices for HR Teams 

The good news? Avoiding these issues when verifying Form I-9s remotely is entirely possible with the right approach. Here’s even more detail on how to avoid the above pitfalls with five related best practices that you can implement today: 

1. Always Document the Remote Verification Process: Keep a log of how each remote I-9 was completed: who conducted the review, when it was completed, what platform was used, and which documents were verified. This documentation is your safety net during audits. 
2. Use Clear Video and Verified Identity Documents: Don’t rush through this process. Ask employees to show original, unexpired documents clearly on camera. Be sure you’re not relying solely on images or PDFs. Examine copies (front and back, if the document is two-sided) of Form I-9 documents or an acceptable receipt to make sure that the documentation presented reasonably appears to be genuine and relates to the employee. Be sure to retain a clear and legible copy of the documentation, front and back if the documentation is two-sided. 
3. Store Documents Securely: Use a digital document management solution that supports secure, encrypted storage. Avoid local drives, and make sure access is restricted to HR or compliance personnel only. 
4. Maintain Audit-Ready Logs: Whether you’re using a spreadsheet or an HRIS, keep consistent records that can be easily accessed during an audit. Include form versions, timestamps, and review notes. 
5. Train Staff or Partner with a Trusted Provider: If your team isn’t confident in handling Form I-9 verification for remote employees, consider outsourcing to a vendor specializing in I-9 compliance. Alternatively, offer internal training and refresher courses on a regular basis. 

What Remote I-9 Verification Means for Your Organization 

Because today’s workforce is increasingly remote and distributed across cities, states, and even time zones, having the flexibility to conduct I-9 verification remotely not only supports this modern work reality, it also helps HR teams streamline onboarding while staying compliant. 

Yes, the rules are more complex than a simple signature on a form. But with the right tools, training, and attention to detail, you can take full advantage of remote I-9 verification without sacrificing compliance. 

In the end, remote and hybrid work is here to stay. So is the need for smart, adaptable HR practices. Whether you're hiring someone across the country or across town, make sure your I-9 process is built for where your workforce, and the law, are going next.