What Employers Need to Know About the Latest Form I-9 and E-Verify Changes

The HR world is experiencing a great deal of change in regulatory and employee documentation. Even small shifts can trip up a business if it doesn't stay alert and up to date. Take, for example, the minor changes made to Form I-9 and E-Verify, parts of the federal government's system for documenting employment eligibility.

In this article, we're going to address the most important changes to Form I-9 and E-Verify, which include:

• Form I-9 and E-Verify have new terminology.
• E-Verify now requires ongoing review of Status Change Reports to confirm that all of the Employment Authorization Documents that they used are still valid.

As these latest changes were put into place, employment law experts predicted an increase in Form I-9 audits by the U.S. Immigration and Customs Enforcement (ICE).

With our expertise, TriNet can help clients navigate Form I-9, E-Verify and other HR-related compliance requirements.

Overview of Recent Form I-9 and E-Verify Changes

Form I-9 is a document all U.S. employers must use to verify the identity and work authorization of all employees within three days of hire. Employees must provide acceptable identity documents to prove they are authorized to work in the United States.

E-Verify is an optional electronic system (though mandatory for federal contractors and in some states) that allows employers to confirm the eligibility of their employees by cross-referencing Form I-9 information against government databases.

U.S. Citizenship and Immigration Services (USCIS) released a revised Form I-9 (edition date 01/20/25, expiration 05/31/2027) with several updates. The most significant changes are:

• Renaming the fourth checkbox in Section 1 from "A noncitizen authorized to work" to "An alien authorized to work" to align with statutory language.
• Revising the descriptions for two List B documents in the acceptable documents section.
• Updating the DHS Privacy Notice in the form instructions.

The new form is available, but employers can continue using previous editions (specifically the 08/01/23 versions that expire on either 05/31/2027 or 07/31/2026) until their respective expiration dates. However, those using the version expiring 07/31/2026 must update their electronic systems with the correct 05/31/2027 expiration date by July 31, 2026.

Corresponding to these form changes, the E-Verify and E-Verify+ systems implemented updates starting April 3, 2025. As on the new Form I-9, the citizenship status option during case creation that was formerly “A noncitizen authorized to work” is now "An alien authorized to work" .

This might create a temporary disconnect where employees may still select the option with the old terminology on older Form I-9 editions while employers must select the new option with the new language in E-Verify.

New E-Verify monitoring requirements

Beyond the terminology updates, E-Verify introduced significant new review capabilities and revocation of certain formerly valid Employment Authorization Documents which require ongoing employer vigilance.

The Status Change Report, initially deployed on June 20, 2025, helps employers identify whether any of their E-Verify cases were created with an Employment Authorization Document (EAD) that has since been revoked by DHS. This change particularly affects certain individuals whose parole has been terminated.

As of July 15, 2025, the report includes an enhanced "Revoked Document Number" field that allows employers to compare their employee's actual EAD card number against the revoked document list to determine if re-verification is required.

The process is straightforward but critical. If the employee's EAD number used for Form I-9 matches the number listed in the Revoked Document Number field, then that EAD has been revoked. The employer must  reverify the employee using Form I-9, Supplement B, Re-verification and Rehires, with a different acceptable List A or C document.

Conversely, if the employee's EAD number differs from the revoked document number in the report, then their EAD remains valid and no re-verification is required until the employment authorization naturally expires.

This new requirement transforms E-Verify from a one-time verification system into an ongoing responsibility to monitor employment eligibility. It adds another layer of compliance complexity for employers who must now regularly review Status Change Reports and manage employment verification (and re-verification) processes throughout the employment relationship.

What the Changes to Form I-9 and E-Verify Mean for Employers

These updates can create potential compliance concerns that employers must navigate carefully. HR personnel must make sure they select the correct status in E-Verify even if the language of the option in E-verify does not match  what employees check on their forms.

Employers using electronic Form I-9 systems face additional documentation requirements, particularly those using forms with the 07/31/2026 expiration date who must update their systems by July 2026 to reflect the correct expiration date.

Non-compliance could result in the same penalties that apply to other Form I-9 violations, including fines ranging from hundreds to thousands of dollars per form. It makes attention to detail crucial.

From an operational standpoint, these updates may temporarily slow onboarding processes as HR teams adapt to the new terminology requirements and train staff on the proper E-Verify selections. Organizations using Web Services applications should prioritize updating their platforms to avoid confusion and prioritize seamless integration between their systems and government databases.

What are the Best Practices for Employers Moving Forward?

Small and medium-sized businesses can proactively manage these regulatory changes by implementing several key practices that strengthen their compliance posture.

• Regularly review Form I-9s and update internal policies. Conduct quarterly reviews of your Form I-9 files to identify incomplete or outdated forms. Establish clear procedures for handling the terminology differences between form editions and E-Verify selections. Create standardized checklists that provide consistency regardless of which employee handles the verification process.
• Train HR staff or work with a PEO for support. Invest in training to keep your internal team current on identity verification requirements and E-Verify enrollment procedures. An experienced professional employer organization (PEO) can provide you best practices on how to navigate the Form I-9 and E-verify complexity and HR compliance requirements.
• Maintain strong document retention and review trails. Implement digital storage systems that can track every step of the Form I-9 process from initial completion through any corrections or updates. Keep detailed records of E-Verify case numbers and results and establish retention policies that meet federal requirements. Documents should be easily accessible during potential government audits. These practices not only demonstrate good faith compliance efforts but can also provide the evidence needed to defend against penalties or enforcement actions.

How a PEO Can Help You Navigate HR Compliance

For small and medium-sized businesses navigating these regulatory changes, a PEO like TriNet can provide support and some peace of mind.

• Built-in compliance support offers automated workflows to assist you early on, helping to prevent potential issues before they become costly mistakes. You receive resources and updates on changes like these, along with best practices for navigating them, helping to ease the burden of constantly monitoring websites and requirements.
• Access to expert HR best practices give you direct support from specialists who understand the nuances of Form I-9 requirements and E-Verify processing. They can offer best practices related to compliance and processes, and help you stay on top of evolving regulations.

Navigate HR Changes with Confidence

Staying up to date with evolving employment-related regulations is a constant challenge for small and medium-sized businesses. They have so many employer responsibilities to juggle.

Government agencies frequently issue updates to federal regulations with minimal notice, and the cost of non-compliance continues to rise. What appears to be a minor terminology change today can lead to penalties and exposure tomorrow if not properly managed.

This is where TriNet can help, combining cutting-edge technology with deep HR expertise to support your compliance needs, so you can focus on growth. TriNet clients have access to the latest resources to help them comply with Form I-9 and E-Verify requirements.

TriNet offers a comprehensive approach that spans from compliance, payroll and HR. With access to our experts and services, you can confident in navigating today’s HR compliance requirements.

To learn more about how TriNet can help you navigate compliance with confidence and mitigate risk, download our free eGuide on compliance and discover the peace of mind that comes with having experienced professionals supporting your HR compliance needs.