I-9 remote verification: the two lawful ways to do it in 2026

There are two lawful ways to complete the document-examination part of Form I-9 without meeting a new hire in person: the DHS alternative procedure, available only to employers enrolled in E-Verify in good standing, and an authorized representative who physically examines the documents on the employer's behalf, available to any employer whether or not it uses E-Verify. There is no version of "remote verification" that skips physical examination of the documents entirely; one of these two options always puts someone's eyes on the original documents, either over live video or in person through a representative. A photo emailed ahead of a video call, on its own, satisfies neither option unless the document is also physically compared, live, to the person holding it.

This page is about the document-examination method, not the deadline for completing it. For when Section 1 and Section 2 are due relative to the start date, see Form I-9 timing in hiring.

The short answer: two lawful options

The DHS alternative procedure, step by step

DHS announced this procedure in a Federal Register notice effective August 1, 2023, and USCIS describes it on its Remote Examination of Documents page and in Handbook for Employers, Section 4.5. To use it:

1. Confirm E-Verify good standing. The employer must be enrolled in E-Verify for every hiring site where it uses the procedure, use E-Verify for its new hires, and be in compliance with E-Verify's own program requirements.
2. Have the employee transmit copies of their documents first, front and back, before the video call.
3. Hold a live video interaction with the employee, during which they present the same physical documents they already transmitted, so the examiner can compare the documents to the copies and confirm they reasonably appear genuine and relate to the person presenting them.
4. Retain clear, legible copies of every document examined this way, for as long as the employer is required to keep I-9 records.
5. Create an E-Verify case for the new hire, as usual.
6. Check the box in Section 2's Additional Information field on the current Form I-9 (the 08/01/2023 or 1/20/2025 edition) indicating the alternative procedure was used.

A short example of how the video call itself typically goes, to set expectations for whoever on your team runs it:

Recruiter: Thanks for sending those document copies ahead of time. Can you
hold up your driver's license, the same one you sent, so I can compare it
to the copy on my screen?

Employee: [holds up license]

Recruiter: Great, that matches. Can you flip it to show the back as well?

Employee: [shows back of license]

Recruiter: Perfect, thank you. That completes the document review — I'll
finish Section 2 on my end and we'll create your E-Verify case today.

The point of the call is comparing the physical document in the employee's hand to the copy already on file, not reviewing the document for the first time. If something does not match, or the document looks altered, stop and ask for a different acceptable document rather than proceeding.

What happened to the COVID-19 temporary flexibilities

Before the permanent alternative procedure existed, DHS ran temporary flexibilities from March 2020 through July 31, 2023, letting many employers examine documents over video call without a formal DHS-authorized procedure. Per USCIS's Q&A on the end of those flexibilities, employers had until August 30, 2023 to complete in-person physical examination of documents for anyone verified under the temporary rules, unless they were enrolled in E-Verify, in which case they could instead apply the new alternative procedure to those same employees starting August 1, 2023, without an in-person meeting. If your organization has been operating since before mid-2023, it is worth confirming that this one-time catch-up was actually completed and documented for every affected employee; a gap here does not fix itself with time.

If you are not enrolled in E-Verify: the authorized representative option

An employer that has not enrolled in E-Verify can still hire someone it will never meet in person. USCIS's Handbook, in Section 2.0, Who Must Complete Form I-9, describes an employer's option to designate an authorized representative, such as a notary public, a colleague near the new hire, or a paid I-9 verification service, to physically examine the original documents in the employee's presence and complete and sign Section 2 on the employer's behalf. The employer remains liable for any error the representative makes, so this option trades the recruiter's own travel for someone else's, rather than eliminating physical examination altogether.

In practice, employers hiring in a state where they have no local staff use one of three kinds of authorized representative: a commercial notary public, found through a mobile-notary service in the new hire's area; a colleague, client contact or another company's employee who happens to be nearby, so long as the employer designates them for the task; or a paid I-9 verification service that specializes in sending a representative to the new hire. Whichever you use, give them the same instruction: examine the original documents in the employee's physical presence, confirm they reasonably appear genuine and belong to the person presenting them, and complete Section 2 the same day. A representative who only reviews a photo the employee texts them, without meeting in person, is not performing the physical examination the regulation requires, and defeats the purpose of choosing this option over the E-Verify alternative procedure.

Consistency, and hybrid workforces

If an employer offers the alternative procedure at a given hiring site, USCIS guidance says it must do so consistently for everyone hired at that site, to avoid the appearance of picking and choosing based on a protected characteristic. An employer can limit the alternative procedure to remote hires specifically, while continuing physical examination for onsite and hybrid staff, as long as that distinction tracks work location rather than a candidate's citizenship status or national origin, and is applied the same way to every remote hire.

Reverification and rehires

An E-Verify employer in good standing may also use the alternative procedure for reverification, checking the corresponding box in Supplement B rather than Section 2. USCIS guidance specifically notes that a new E-Verify case should not be created for a reverification, only for a new hire, so treat reverification as a distinct step from onboarding even when the same video-call process is used for both.

A checklist before you verify a remote hire's documents

• Confirm whether your organization is enrolled in E-Verify in good standing at the hiring site involved.
• If yes, use the DHS alternative procedure: transmitted copies first, then a live video call comparing the documents to the person, retained copies, an E-Verify case, and the Section 2 box checked.
• If no, arrange an authorized representative to examine the documents in person and complete Section 2, and confirm they understand they are acting on the employer's behalf and the employer remains responsible for errors.
• Apply whichever method you choose consistently across a given hiring site, documented by work location rather than by individual discretion.
• For any employee verified under the 2020–2023 COVID-19 flexibilities, confirm the required catch-up, in-person or via the alternative procedure, was completed by the prior deadline and is documented.
• Route reverification through Supplement B, not a new Section 2 or a new E-Verify case.
• Retain the copies you examined for as long as the underlying I-9 record is required: three years after the date of hire, or one year after employment ends, whichever is later.
• Check uscis.gov and e-verify.gov directly before relying on this page well after September 2026; USCIS updates I-9 guidance and forms periodically.
• Put the decision, alternative procedure or authorized representative, in a written internal policy, so a new hiring manager does not improvise a third approach that satisfies neither option.

USCIS's own page on Retaining Form I-9 sets that same three-years-or-one-year rule for the form itself, and the document copies kept under the alternative procedure are part of that same record, not a separate file with its own schedule. A staffing agency running remote verification across multiple states should keep the retention calculation centralized, since it is easy for a branch office to purge files on its own schedule rather than the federal one.

For agency placements specifically, including E-Verify's application to staffing arrangements, see contractor onboarding checklist for staffing agencies.