How Often Do I-9 Forms Need to Be Updated or Reverified?

Form I-9 does not run on a schedule. There is no annual refresh, no five-year renewal, no recurring update requirement. How often an I-9 needs to be updated depends entirely on events: a work authorization document expiring, a rehire, a corporate acquisition, or a discovered error. For most employees, once the form is completed correctly at hire, it is never touched again.

The initial deadlines are fixed. The employee finishes Section 1 no later than their first day of work, and the employer completes Section 2 within three business days of the hire date.¹ After that, updates only happen when something triggers them.

What Triggers a Required Update

Expiring Work Authorization

The most common trigger is the expiration date of a work authorization document the employee originally presented. If Section 1 or Section 2 shows an expiration date for the employee’s work authorization, the employer must reverify no later than that date. The employee presents a current, unexpired document from List A or List C, and the employer records the new document on Supplement B. An employer who fails to reverify on time cannot legally continue employing that person.²

Automatic EAD Extensions

Employees who timely filed an EAD renewal application before October 30, 2025, may have received an automatic extension of up to 540 days from their EAD’s expiration date. When the employee shows a Form I-797C receipt notice reflecting this extension, the employer records “EAD EXT” and the new expiration date in the Section 2 Additional Information field. Reverification is then due when the automatic extension ends or when USCIS decides the renewal application, whichever comes first.³

Rehires Within Three Years

If you rehire someone within three years of the date their previous Form I-9 was completed, you can either complete a new form or fill out Supplement B on the existing one.⁴ Past that three-year mark, a new form is required, because the retention period for the old one has likely run out.

Mergers and Acquisitions

When one company acquires another, the successor employer picks a path for existing employees. Option A treats everyone as a new hire and completes a new I-9 for each, using the acquisition’s effective date as the first day of employment. Option B treats them as continuing employees and keeps the original forms on file, which means the successor also inherits responsibility for any errors on those forms.⁵

Who You Should Never Reverify

Reverifying the wrong people is one of the most common I-9 mistakes, and it can amount to unlawful discrimination based on citizenship status or national origin.⁶ Do not reverify:

U.S. citizens and noncitizen nationals. Their right to work does not expire.
Lawful permanent residents who presented a Permanent Resident Card (Form I-551). The card may expire, but permanent resident status does not.
List B documents. These establish identity only, not work authorization, so they are never used for reverification.

Asking a lawful permanent resident for a new green card because the old one expired, or asking a U.S. citizen for new documents because their driver’s license expired, is a documentary practice violation. The employee always chooses which acceptable document to present.⁷

Changes That Do Not Require Any Update

Plenty of routine employment events have nothing to do with work authorization. Promotions, transfers, raises, and address changes do not require any I-9 activity.⁸

A legal name change is a near miss. It does not require reverification, because the employee’s work authorization has not changed. USCIS recommends noting the new name in Supplement B so the form stays accurate, but failing to record it is not a violation.

How to Complete the Update

Reverifications and rehire updates go on Supplement B, which replaced the old Section 3. Write the employee’s full name from the original Form I-9 at the top. Record the new document’s title, number, and expiration date. Then sign and date the supplement.⁹

Additional blocks on the same Supplement B handle future reverifications, and extra supplement sheets can be attached as needed. If the original Form I-9 was completed on an edition that is no longer valid, use the current version of Supplement B and attach it to the original.²

Fixing Errors on a Past Form

Correcting mistakes is separate from updating. If you find an error on a completed I-9, fix it as soon as you discover it. Draw a line through the incorrect information, write the correct information nearby, and initial and date the change. Never use correction fluid or erase. Only the employee (or their preparer or translator) can correct Section 1. Only the employer can correct Section 2 or Supplement B.¹⁰

If a form has so many errors that corrections would make it illegible, complete a new form and attach it to the old one with a written explanation. For a missing completion date in Section 2 or Supplement B, enter the current date rather than backdating, and initial the field. Attach a signed and dated note explaining any correction.

When the Form’s Life Actually Ends

Updates stop mattering once the retention period runs out. After an employee leaves, keep their Form I-9 for three years from the hire date or one year after their last day of work, whichever is later.¹¹ A quick shortcut: if someone worked less than two years, the three-years-from-hire rule controls; if more than two years, keep the form for one year after their last day. USCIS recommends storing I-9s separately from general personnel records so you can produce them within three business days of a request from DHS, the Department of Justice, or the Department of Labor.¹²

What Missing an Update Costs

Paperwork violations, which include failing to reverify on time, currently carry fines from $288 to $2,861 per form after inflation adjustments to the base statutory range of $100 to $1,000.¹³ Amounts depend on business size, good faith, seriousness, and prior violation history.¹⁴

Knowingly continuing to employ an unauthorized worker, which is what happens when a required reverification is skipped and the employee’s authorization has actually lapsed, costs far more:

First offense: $716 to $5,724 per worker
Second offense: $5,724 to $14,308 per worker
Third or subsequent offense: $8,586 to $28,619 per worker

A pattern or practice of knowingly employing unauthorized workers can also bring criminal prosecution, with fines up to $3,000 per worker and imprisonment of up to six months.¹³ Because the schedule is event-driven rather than calendar-driven, the practical safeguard is a tracking system tied to each employee’s document expiration date, not a recurring compliance sweep.

1
U.S. Citizenship and Immigration Services. Completing Section 1, Employee Information and Attestation
2
U.S. Citizenship and Immigration Services. 6.1 Reverifying Employment Authorization for Current Employees
3
U.S. Citizenship and Immigration Services. 5.1 Automatic Extensions Based on a Timely Filed Application to Renew Employment Authorization
4
U.S. Citizenship and Immigration Services. Completing Supplement B, Reverification and Rehires (Formerly Section 3)
5
U.S. Citizenship and Immigration Services. 8.0 Rules for Continuing Employment and Other Special Rules
6
U.S. Citizenship and Immigration Services. Types of Employment Discrimination Prohibited Under the INA
7
Department of Justice. How to Avoid Discrimination in the Form I-9 and E-Verify Processes
8
U.S. Citizenship and Immigration Services. 6.3 Recording Changes of Name and Other Identity Information for Current Employees
9
U.S. Citizenship and Immigration Services. Form I-9, Employment Eligibility Verification
10
U.S. Citizenship and Immigration Services. 9.0 Correcting Errors or Missing Information on Form I-9
11
USCIS. 10.0 Retaining Form I-9
12
U.S. Citizenship and Immigration Services. Retention and Storage
13
Office of the Law Revision Counsel. 8 USC 1324a – Unlawful Employment of Aliens
14
U.S. Immigration and Customs Enforcement. Form I-9 Inspection Under Immigration and Nationality Act Section 274A