Form I-9 without a Social Security number: who can start work, when E-Verify waits, and how payroll copes

Yes, a new hire can complete Form I-9 and start work without a Social Security number. If you do not use E-Verify, the Social Security number field in Section 1 is voluntary. If you do use E-Verify, an employee who has applied for a number but not received it leaves the field blank, works while waiting, and adds the number later; only the E-Verify case waits. What you should not do, as of November 2026, is make having a number or a Social Security card a condition of completing Form I-9 or starting work, or accept an ITIN in its place.

This page works through the Form I-9, E-Verify and payroll steps for a hire without a number yet. The field-by-field walk-through of Section 1 is in Form I-9 Section 1 instructions, and why SSA's verification service is not a pre-hire screen is in can employers use SSNVS to screen applicants.

Can a new hire complete Form I-9 without a Social Security number?

Yes. M-274 Section 3.0 says "employees may voluntarily provide their Social Security number or leave this field blank," and that "employees who have not yet received their Social Security number and who can satisfy all other Form I-9 requirements may work while awaiting their Social Security number." The exception is E-Verify: if you are enrolled, employees must provide the number, but the Form I-9 instructions say someone who has applied and not yet received it leaves the field blank and "may begin working while waiting to receive your Social Security number."

The people this happens to are usually work-authorized and new: newly arrived immigrants, recent permanent residents and refugees. IER's best practices for recruiting and hiring mention newly arrived permanent residents and refugees and warn that "unnecessarily requiring a Social Security number to apply for or start a job could create an unwarranted obstacle." The refugee-specific documents, including the refugee I-94 receipt, are in Form I-9 for refugees and asylees. SSA's leaflet Social Security Numbers for Noncitizens (February 2026) says applying is free, that immigrant visa applicants can apply through their visa application, and that others may want to wait 10 days after arriving so SSA can verify their DHS documents online.

What goes in Section 1 and Section 2?

• Section 1, no E-Verify: the employee may leave the field blank. Do not press for it, and do not fill it in from payroll records.
• Section 1, E-Verify: blank until the number arrives, then the employee enters it and initials and dates the entry, per the Form I-9 instructions.
• Never an ITIN. The instructions say, "Do not enter an Individual Taxpayer Identification Number (ITIN) as your Social Security number."
• Section 2 is unaffected. The employee still presents one List A document, or one List B plus one List C document, of their choice. A Social Security card is only one of several List C options, so a person with no card can complete Section 2 with, for example, a List A document.
• No receipt for a first card. USCIS's List C receipt covers a replacement for a lost, stolen or damaged document (M-274 13.3). A receipt for a first-time Social Security card application is not on the list; see the I-9 receipt rule.

The handbook also closes a common side door: "You cannot ask employees to provide a specific document with their Social Security number on it. To do so may constitute unlawful discrimination."

What if you use E-Verify?

The E-Verify User Manual, Section 2.1 gives the procedure for a new hire who "has applied for, but has not yet received an SSN":

1. Complete Form I-9 on the normal timeline, with the Section 1 number field blank.
2. Attach an explanation to the employee's Form I-9 and set it aside.
3. Let the employee keep working. IER's Form I-9 and E-Verify fact sheet says employees who present sufficient documents and are waiting for their number "have satisfied the Form I-9."
4. When the number arrives, have the employee add it to Section 1 with their initials and the date.
5. Create the case "as soon as it is available." If that is after the third business day after the start of work for pay, choose Awaiting Social Security Number from the reason-for-delay list (User Manual, Section 2.2).
6. Check the number against the card or the employee's own entry before you submit. ICE's inspection fact sheet lists, among technical failures, an E-Verify employer's failure to ensure the employee's Social Security number is correct.

Do not create the case with a placeholder number, and do not hold back the start date until the number comes. The wait applies to the E-Verify case, not to the job; E-Verify vs. Form I-9 explains how the two processes fit together.

How does payroll report wages before the number arrives?

Payroll and Form I-9 have different jobs here, and mixing them is where trouble starts. IRS Publication 15 (2026), section 4, says:

• "You're required to get each employee's name and SSN and to enter them on Form W-2."
• If the employee applied for a number but does not have one when Form W-2 is due, enter "Applied For" on a paper form, or all zeros in the SSN field if you file electronically. When the number arrives, file Form W-2c with SSA and give the employee copies.
• "Don't accept an ITIN in place of an SSN for employee identification or for work."
• You "should ask your employee to show you their social security card, but the employee isn't required to show the card if it isn't available."

Keep that payroll request separate from the Form I-9. Payroll can ask for the number; it cannot turn the Social Security card into the employee's required Form I-9 document. Record the name and number exactly as they appear on the card once you have them, and see SSA no-match letters if the number later fails to match SSA's records.

Which situations look similar but need different handling?

A worked example

The dates and people are illustrative. An employer enrolled in E-Verify hires a newly arrived permanent resident who starts on Monday, February 1, 2027. She has no Social Security card yet.

• Day one: she completes Section 1 with the number field blank. On day two she presents her foreign passport with the temporary I-551 printed notation on her immigrant visa, a List A document, and HR completes Section 2.
• The same day: HR attaches a short note to the form ("SSN applied for, E-Verify case pending"), sets a weekly reminder, and payroll sets her up without a number.
• February 16: her card arrives. She enters the number in Section 1 and initials and dates it. HR creates the E-Verify case that day and selects Awaiting Social Security Number as the reason for the delay.
• Payroll: records the name and number exactly as shown on the card. Because the number arrived long before any Form W-2 is due, no "Applied For" entry or W-2c is needed.

Nobody asked her for the card itself for Form I-9, her start date did not move, and the only thing that waited was the E-Verify case.

What should HR, payroll and recruiters avoid?

• An application or onboarding form that cannot be submitted without a Social Security number.
• Moving a start date, or ending employment on day four, because the number has not arrived.
• Asking for the Social Security card for Form I-9, or asking only noncitizens for it.
• Entering an ITIN, a made-up number or another person's number anywhere on Form I-9.
• Running an applicant through SSNVS or E-Verify before hire; both are for hired employees only.
• For staffing agencies, letting each branch improvise. Write one rule for hires without a number, and a tracker so the E-Verify case and the W-2c are not forgotten once the number arrives.

A short checklist

• Section 1 blank (or the number, if given); no ITIN.
• Section 2 completed within three business days with documents the employee chose.
• E-Verify employers: explanation attached, case diaried, created when the number arrives, delay reason selected.
• Payroll: "Applied For" or zeros if a W-2 is due before the number; W-2c afterwards.
• Same procedure for every new hire, regardless of citizenship status or national origin.