E-Verify requirements in Kansas: no mandate after SB 196 and HB 2066 died, and why Missouri still matters

As of October 2026, Kansas does not require E-Verify. The closest the state has come recently was a 2025 push by the Attorney General's office: Senate Bill 196 and its House twin, House Bill 2066, would have required every business and public employer in Kansas to use E-Verify and tied compliance to state licenses and income tax deductions. Both bills are listed as "Died" on the Legislature's website. Kansas also has no law limiting employers that use E-Verify voluntarily.

The practical complication is geography. The Kansas City metro sits on a state line, and on the Missouri side a public contract above $5,000 carries an E-Verify requirement. Kansas recruiters who staff both sides need to track which state's law governs which worker.

Kansas at a glance

What SB 196 would have done

SB 196 was a Senate Federal and State Affairs Committee bill requested by the committee chair, Senator Mike Thompson. Its title described it as "requiring business entities and public employers to register and use the e-verify program for employment purposes and prohibiting income tax deductions for wages and remuneration paid to unauthorized aliens." The fiscal note summarizes the main pieces:

• Universal enrollment. All businesses and public employers would have used E-Verify beginning July 1, 2025, keeping associated documentation for up to three years and producing it to the Attorney General or a county or district attorney on request.
• License consequences. Not using E-Verify or not keeping records could have led to suspension of the business's state licenses for between ten days and one year. Knowingly hiring an unauthorized alien carried escalating court-ordered license suspensions, ending in permanent suspension and revocation of the business's registration as a corporation, LLC or limited partnership for a third violation.
• State contracts. State agencies could not have entered into new contracts for services unless the contractor used E-Verify.
• Tax affidavit. Businesses would have filed an affidavit with the Department of Revenue covering E-Verify enrollment and use for hires since July 1, 2025, with deductions added back if the affidavit was knowingly false.

The Senate committee heard the bill on March 6, 2025, with testimony from the Attorney General's office, business groups and the League of Kansas Municipalities, and took up a balloon amendment on March 17, 2025. The Legislature's page shows only the "Introduced" stage as complete, with no committee report or floor action. HB 2066, carrying the same title and requested on behalf of the Attorney General's office in the House Federal and State Affairs Committee, never advanced either. The 2025-2026 biennium has ended, so any new attempt would start over in 2027.

The Kansas City problem: Missouri's contract rule

Missouri's E-Verify statute, RSMo 285.530, applies to public employers and to businesses that receive a state or local contract or grant above $5,000, as well as to recipients of certain state-administered tax credits, abatements and loans. Missouri amended its enforcement provisions effective August 28, 2026. A Lenexa or Overland Park firm that performs work under a contract with Kansas City, Missouri, Jackson County or a Missouri state agency needs to look at the Missouri rule for that contract, not the Kansas one. The detail, including what a Missouri contractor must submit and how the 2026 amendments changed enforcement, is in E-Verify requirements in Missouri.

Kansas's other borders add similar public-sector rules. Nebraska requires E-Verify of public employers and public services contractors with no dollar threshold, and Oklahoma requires it of public employers and of contractors and subcontractors on public services contracts. Colorado repealed its public-contract verification law in 2022. A Wichita firm bidding in Oklahoma, or a western Kansas agricultural contractor working in Nebraska, faces those states' rules on that work.

Federal work in Kansas

Federal installations and federal construction in Kansas bring the federal clause into the state regardless of the Legislature. FAR 22.1803 places FAR 52.222-54 in contracts above $150,000, except those performed entirely abroad, those under 120 days, and those only for commercially available off-the-shelf items. Covered prime contractors flow it down to subcontracts for services or construction above $3,500 with work in the United States, and must enroll within 30 days of award. For a Kansas base support contractor, that means verifying company-wide new hires and employees assigned to the contract, whatever Kansas law says.

What every Kansas employer still does

Form I-9 is completed for every hire, with the employer's review of documents within three business days of the start date. A Kansas employer that enrolls in E-Verify voluntarily does so under the federal memorandum of understanding: every new hire at the enrolled site, no case before an accepted offer and a completed I-9, no adverse action while a tentative nonconfirmation is being contested, and records kept with the I-9. Kansas adds nothing to that and takes nothing away.

If the bill comes back: what to have ready

SB 196 reached past an employer's own hiring to its independent contractors and its tax return. Under the fiscal note's description, the Department of Revenue affidavit would have asked a business to confirm that any independent contractor it paid was itself registered with and using E-Verify. For staffing firms, recruiters who use 1099 sourcers, and construction businesses that rely on subcontracted crews, that would have been a bigger lift than enrolling their own hiring sites. A business that wants to be ready for a revived bill without enrolling today can:

• List every regular independent contractor and note whether each one is enrolled in E-Verify.
• Clean up Form I-9 practice now, since any E-Verify case runs from the I-9 data and an audit would start there.
• Decide in advance which locations would be registered as hiring sites if enrollment became mandatory.
• Inventory state and local licenses, because license suspension was the bill's main enforcement lever.

Staffing agencies in Kansas

• Kansas placements carry no state E-Verify duty.
• Missouri placements under a Missouri public contract or grant above $5,000 can, and the agency, as employer of record, is the one that would enroll. Check whether the client's Missouri contract requires its subcontractors to comply too.
• An agency that enrolls for one Missouri contract binds every new hire at the enrolled hiring site. Some agencies keep their Missouri branch as a separate hiring site for that reason; see E-Verify for staffing agencies.
• Kansas licensing rules for employment agencies are separate; see staffing agency license requirements in Kansas.

A worked example

This is an invented example. An Overland Park light-industrial staffing firm has two branches: one in Olathe serving Kansas warehouses, and one in Kansas City, Missouri that has just won a $60,000 contract to supply temporary custodial staff to a Missouri public school district. The Olathe branch has no E-Verify requirement under Kansas law and continues with Form I-9 only. For the Missouri contract, the firm enrolls the Kansas City, Missouri branch as an E-Verify hiring site, provides the E-Verify documentation the district asks for, and verifies every new hire at that branch from then on. If SB 196 had passed, both branches would have been covered from July 2025; because it died, only the Missouri side is.

A Kansas checklist

1. Kansas-only work with no federal clause: E-Verify is optional; Form I-9 is required.
2. Any contract or grant from a Missouri public body above $5,000: apply Missouri's statute to that work.
3. Public contracts in Nebraska or Oklahoma: check those states' contractor rules.
4. Any federal prime or subcontract: look for FAR 52.222-54 and enroll within 30 days if it is there.
5. Watch the 2027 session for a revived version of SB 196.
6. Compare all states in E-Verify requirements by state.