How to convert paper I-9s to electronic storage: purge first, then scan to 8 CFR 274a.2

To convert years of paper Forms I-9 to electronic storage, sort the archive before you scan anything. Destroy the forms of former employees whose retention period has ended (three years after hire or one year after employment ended, whichever is later), audit and correct the rest on paper, then scan only the completed pages, supplements and any document copies into a system that meets 8 CFR 274a.2(e), (f) and (g): reasonable controls, an index, legible reproduction, written documentation and an audit trail. USCIS's Handbook for Employers says you may destroy each paper original once it is securely stored electronically. In an archive that goes back 20 years, every former employee hired more than three years ago who left more than a year ago is past retention, so the purge step can remove a large share of the boxes before a single page is scanned.

The requirements an electronic I-9 system must meet are covered paragraph by paragraph in electronic I-9 storage requirements, and the retention formula in I-9 retention rules. This page is the conversion project itself: the order of work, the retention math applied to an old archive, and when the paper can go.

Do you have to convert paper I-9s at all?

No. Section 274a.2(b)(2)(i) allows a paper form "with original handwritten signatures," an electronic form, "original paper scanned into an electronic format," "a combination of paper and electronic formats," or microfilm or microfiche. Converting is worth it when storage space, inspection speed or a planned move to an electronic I-9 system makes paper a burden. It is not worth doing badly: a scan that is illegible or cannot be found by an index is a weaker record than the paper it replaced, and once the paper is shredded it cannot be fixed.

Step 1: Which old I-9s can you destroy instead of scanning?

The forms of former employees whose retention period is over. The rule in 274a.2(b)(2)(i)(A) is three years after the date of hire or one year after the date employment ended, whichever is later. USCIS's Handbook section 10.0 turns that into a shortcut: if the person worked for you less than two years, keep the form three years after the first day of employment; if more than two years, keep it one year after they stopped working for you. It also says: "Never dispose of a current employee's Form I-9."

Sort the archive into three piles, using payroll's hire and termination dates rather than the forms themselves:

Worked examples, as of October 30, 2026 (invented employees):

• Hired March 3, 2008, left June 30, 2012. Three years from hire is March 3, 2011; one year from leaving is June 30, 2013. The later date has passed: destroy.
• Hired April 1, 2019, left September 30, 2025. Three years from hire is April 1, 2022; one year from leaving is September 30, 2026. That has now passed: destroy.
• Hired January 15, 2024, left February 2, 2025. Three years from hire is January 15, 2027; one year from leaving is February 2, 2026. The later date is January 15, 2027: scan and keep until then.
• Hired July 1, 2007, still employed. Keep, however old the form is.

Three edge cases. For a rehire whose original form you updated rather than replacing it, 274a.2(c)(2) runs the three years "from the date of the initial execution of the Form I-9" (see I-9 for rehires). A recruiter or referrer for a fee, as opposed to the employer, keeps the form three years after the date of hire under 274a.2(b)(2)(i)(B). And the Handbook's requirement covers employees hired after November 6, 1986, so a very old archive may contain forms that were never required. Before you shred anything, check with legal for holds: an open inspection, a discrimination charge, litigation or a pending acquisition can all require you to keep records past their date.

Step 2: Should you fix errors before you scan?

Yes. Scanning preserves whatever is on the page, so this is the cheapest moment to audit. USCIS's Handbook section 9.0 sets the method: only the employee (or their preparer or translator) corrects Section 1, only the employer corrects Section 2 and Supplement B, and the correction is made by drawing a line through the incorrect information, entering the correct information, and initialing and dating it, with a written explanation attached. If the employee has left, attach a signed and dated statement identifying the error and why it could not be corrected. Never erase, white out or backdate. What to look for, form by form, is in the I-9 audit checklist and common I-9 mistakes.

Do not have current employees fill out new forms because you are converting. The regulation asks you to keep "the original signed version" of the form, and a scan of the original, with its corrections visible, is what an inspector expects to see.

Step 3: Which pages and documents do you scan?

• Only pages with data on them. Section 274a.2(e)(1) lets you retain electronically "only those pages of the Form I-9 on which employers and employees enter data," and the Handbook says you "do not need to keep the Lists of Acceptable Documents on page 2, the instructions or blank supplement pages."
• Completed supplements and reverification sections, including older Section 3 pages on earlier editions of the form.
• Correction memos and explanation statements stapled to the form.
• Copies of identity and work authorization documents, if you kept them. Under 274a.2(b)(3), a copy you made "must either be retained with the Form I-9 or stored with the employee's records" and be retrievable to the electronic standards. The Handbook's section 10.2 adds that copies kept for reasons unrelated to E-Verify must be kept for all employees, not selectively.
• E-Verify case printouts, if your practice was to keep them with the form.

Step 4: What must the system holding the scans do?

The same standards apply to scanned paper as to forms born electronic. For a conversion, five parts of 274a.2(e)–(g) matter most:

Also check (e)(3): the system must not be subject to any contract or license that would limit a federal agency's access to it. A shared drive of PDFs with no index, no access control and no audit trail does not meet these standards, however tidy the folder names are.

Step 5: How do you check the scans before shredding?

Section 274a.2(e)(1)(iii) asks for "an inspection and quality assurance program evidenced by regular evaluations" of the system, "including periodic checks" of the stored forms. For a one-time conversion, build the check into each batch:

1. Count pages in and pages out for each batch.
2. Open every form and confirm it is legible, complete and indexed to the right person; for a large archive, at least confirm every record retrieves by name and ID and review the images of a sample of each batch in full.
3. Retrieve a handful of records by index search, the way an inspector's request would arrive.
4. Have someone other than the scanner sign off the batch, with the date.
5. Keep the paper for that batch until the sign-off is done.

Step 6: When can you destroy the paper originals?

After the electronic copy is securely stored. The Handbook's section 10.1 says: "You may destroy the original paper form after you have securely stored it in an electronic format." Shred rather than recycle, since the forms carry Social Security numbers, birth dates and document numbers, and keep a destruction log: batch, date range of forms, date destroyed, who did it. Treat the past-retention pile from step 1 the same way.

A project plan for a 20-year archive

For new hires after the conversion, either complete the form on paper and scan it on the same terms, or move to an electronic I-9 with signatures that meet 274a.2(h) and (i). A typed name on an emailed PDF does not; USCIS's Form I-9 page says its own fillable form must be printed and signed by hand because it does not meet those standards.

What does an inspection look like after you convert?

The notice period does not change: under 274a.2(b)(2)(ii) you get at least three business days' notice. What changes is what you hand over. Under (e)(8), you retrieve and reproduce only the forms and supporting documents requested, "along with associated audit trails," provide the hardware, software, personnel and documentation needed to read them, and, if asked, a reasonably available electronic summary file such as a spreadsheet. Penalties for paperwork violations are in I-9 penalties.

Common mistakes in I-9 conversions