How to verify staffing agency workers: what the agency must check and what the client should check

As the client, you verify staffing agency workers mainly through the agency, not around it. The agency is the employer, so it completes Form I-9, any E-Verify case and any background checks; your contract should require it to verify identity before the first assignment, send you each worker's name and profile photo, and confirm those steps in writing. On day one, compare the person who arrives with that profile during the sign-in or badge process everyone goes through. Do not re-run the I-9 or ask temps for work authorization documents, and send any mismatch back to the agency. This reflects USCIS, OSHA, EEOC and FBI guidance as of October 2026 and is not legal advice.

Which party runs E-Verify in each arrangement is covered in E-Verify for staffing agencies, and how responsibility is shared more broadly in joint employer liability for staffing agencies. This page is written for the client site: the hiring manager, supervisor or procurement lead who wants to know the right person turned up.

Who is responsible for verifying a temp worker?

The I-9 line surprises some clients. USCIS's Handbook for Employers tells employers not to complete Form I-9 for people "employed by a contractor providing contract services (such as employee leasing or temporary agencies)" who are providing labor to you. That does not make the client indifferent: federal law says a person or entity that uses a contract "to obtain the labor of an alien in the United States knowing that the alien is an unauthorized alien" is considered to have hired that person in violation of the law (8 U.S.C. 1324a(a)(4)). The practical answer is to require verification from the agency and act on what you learn.

Safety is explicitly shared. OSHA's temporary worker page says staffing agencies and host employers "are jointly responsible for maintaining a safe work environment for temporary workers," including training, hazard communication and recordkeeping. If a temp will drive a forklift or work with hazardous materials, verifying their training is part of your job too.

What should the staffing contract require?

The FBI's January 2025 guidance tells companies to "verify third-party staffing firms conduct robust hiring practices and routinely audit those practices." In contract terms, that means clauses like these:

• Identity before assignment. The agency verifies each worker's identity before the first assignment, live and with photo ID (in person, or on camera for remote work), and keeps a record that it did.
• Profile before start. The agency sends the worker's name, start time and a profile photo, with the worker told that it will be shared for site identification.
• No substitutions without notice. A different person never arrives in place of the confirmed worker; the agency sends a new profile first.
• Employment eligibility. The agency completes Form I-9 and, where enrolled or required, E-Verify for its employees and confirms this in writing on request, without sending documents or case details.
• Background checks and credentials. The scope of checks, which licenses or certifications must be verified, and who orders reports and sends any FCRA notices.
• Incident notice and cooperation. Each side tells the other promptly about suspected identity fraud, and the agency cooperates with any investigation.
• Audit. The client may review the agency's verification process, not individual workers' documents.

Do not write criteria into the contract that you could not lawfully apply to your own employees. The EEOC's guidance on contingent workers says the client "is liable if it sets discriminatory criteria for the assignment of workers," and that it is no defense for the agency that a discriminatory practice came from the client.

How do you run a day-one check at your site?

1. Before the shift, the supervisor or front desk has the agency's list: names, start times and profile photos.
2. At sign-in, every worker and visitor shows photo ID for a badge, as your site rules already require. Check that the name matches the list and the face matches the ID and the profile.
3. Do it by eye. Use a human comparison, not face-recognition software. Scanning face geometry can bring biometric privacy laws into play; Illinois's Biometric Information Privacy Act, for example, requires written notice and a written release before a private entity collects a biometric identifier.
4. Record it. "Worker [name] signed in [date/time], ID and profile matched, checked by [name]."
5. If something doesn't match, do not argue with the worker. Politely hold the start, call the agency's on-call contact, and let them sort it out.

"Thanks for coming in. The name on our list from [agency] doesn't
match what I have here, so I need to check with them before we get
you started. Can you wait in the break room for a few minutes?"

For remote contract workers, the same check happens on camera at the first meeting, and company equipment goes only to the address on the worker's ID. The FBI's July 2025 guidance asks companies using contracted IT workers to educate the third-party company about its recommendations, which include that shipping rule. More detail is in how to verify a remote candidate's location.

What should the client not do?

• Don't redo the I-9 or ask temps for work authorization documents. USCIS's Handbook for Employers lists requesting "more or different documents" than Form I-9 requires, or a particular document, among unfair documentary practices when based on citizenship, immigration status or national origin.
• Don't ask about citizenship, birthplace or immigration status at the gate or on the floor. Site identification is about who the person is, not where they come from.
• Don't keep copies of IDs unless your site security policy requires it for everyone, and then protect them.
• Don't reject or "send back" workers for reasons you could not apply to employees. The EEOC guidance says the client must treat the staffing firm's workers in a non-discriminatory manner.
• Don't confront a suspected impostor alone. Hold the start and escalate.

What happens when a worker isn't who the agency said?

Keep the person off site systems and equipment, tell the agency the same day with facts only, and ask what verification it ran. If the worker already has access to systems or data, bring in your security team before anyone tells the worker about the concern; the steps are in what to do when a new hire is not the person you interviewed, which applies to temps on assignment too. Where an organized scheme is suspected, the FBI asks for reports at ic3.gov. Afterwards, review the agency's process with them: where did the check fail, and what will change?

Questions to ask your staffing agency

For identity checks by hiring stage, which a good agency should already run, see the candidate identity verification checklist.