Supplement B of Form I-9 is the page an employer uses to reverify a current employee whose work authorization is about to expire, or to record a rehire within three years of the original Form I-9. It replaces what used to be called Section 3. You attach it to the employee’s existing I-9 rather than starting a new form, and each block on the page can be used only once.
When to Use Supplement B for Reverification
Federal regulations require you to reverify an employee’s employment authorization no later than the date it expires.1eCFR. 8 CFR 274a.2 – Verification of Identity and Employment Authorization If a worker’s Employment Authorization Document or other time-limited work permit is coming up on its expiration date, complete a block of Supplement B to record the new document and confirm continuing eligibility. You cannot keep someone on the payroll past the expiration date without proof of current authorization.2U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 6.1 Reverifying Employment Authorization for Current Employees
USCIS recommends notifying the employee at least 90 days before reverification is due.3U.S. Citizenship and Immigration Services. Completing Supplement B, Reverification and Rehires Replacement documents from USCIS can take weeks or months, and a last-minute notice may leave the worker without options.
Who You Do Not Reverify
Some employees never trigger this process. Do not reverify U.S. citizens, noncitizen nationals, or lawful permanent residents who presented a Permanent Resident Card (Form I-551) during initial verification.3U.S. Citizenship and Immigration Services. Completing Supplement B, Reverification and Rehires The same goes for List B identity documents, which establish identity and never need reverification on their own. A Permanent Resident Card may carry an expiration date, but the resident’s right to work does not expire with it. Asking for a new card is document abuse, not diligence.
The Receipt Rule
If an employee’s document was lost, stolen, or damaged, they can present a receipt showing they applied for a replacement. That receipt gives 90 days from the expiration of employment authorization for the employee to present the replacement document or another acceptable List A or List C document.4U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 4.4 Acceptable Receipts Record the receipt at first, then update Supplement B when the actual document arrives.
When to Use Supplement B for a Rehire
When a former employee returns, you may use Supplement B instead of completing a new I-9 — but only if the rehire falls within three years of the date the original I-9 was completed.3U.S. Citizenship and Immigration Services. Completing Supplement B, Reverification and Rehires The three-year clock runs from the date the employee originally filled out the form, not their last day of work. Using the supplement is optional; you can always start a fresh I-9 if that is cleaner.
Once three years and a day have passed since the original form was completed, the supplement is off the table. You must start a new I-9 from scratch, running through Sections 1 and 2 as if the employee were brand-new. Using Supplement B outside the window is a substantive violation and can draw fines during an audit.
If the returning employee’s work authorization has expired since they last worked for you, you also need to reverify as part of the rehire, even inside the three-year window. In that case, record both the rehire date and the new document information in the same block of Supplement B.
How to Complete Supplement B
Download the current Form I-9 from the USCIS website. The 01/20/2025 edition is the current version, and the 08/01/2023 edition remains valid through its printed expiration date.5U.S. Citizenship and Immigration Services. I-9, Employment Eligibility Verification Supplement B sits on page 4. Before completing any block, write the employee’s last name, first name, and middle initial at the top of the page.3U.S. Citizenship and Immigration Services. Completing Supplement B, Reverification and Rehires
Each block has three areas that map to different situations. Use the New Name fields if the employee has had a legal name change since the original I-9, either on its own or alongside a reverification or rehire.6U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 6.3 Recording Changes of Name and Other Identity Information for Current Employees For a rehire, enter the Date of Rehire, meaning the date the employee begins working for pay again. That can be a future date if you are completing the form ahead of the start date. For reverification, ask the employee to present any unexpired List A or List C document of their choice, then record the document title, number, and expiration date (if any).3U.S. Citizenship and Immigration Services. Completing Supplement B, Reverification and Rehires
After completing the relevant fields, sign and date the block. The date you enter is the date you actually complete and sign the attestation.3U.S. Citizenship and Immigration Services. Completing Supplement B, Reverification and Rehires Each block can only be used once. If you need to reverify the same employee again later, use the next available block or attach another Supplement B page.
Remote Examination of Documents
Employers enrolled in E-Verify in good standing may examine documents remotely under a DHS-authorized alternative procedure instead of in person.7U.S. Citizenship and Immigration Services. Remote Examination of Documents If you use it for a reverification or rehire, check the designated box on Supplement B (available on the 08/01/2023 and 01/20/2025 editions). The procedure applies only at E-Verify hiring sites. Do not create a new E-Verify case for reverifications, whether the examination is in person or remote.
Handling Automatic Extensions
Some employees’ work authorization is extended automatically, and recording it correctly on Supplement B trips up a lot of employers.
When an employee files a timely renewal application for an Employment Authorization Document, the existing EAD may be extended while USCIS processes the renewal. For applications filed before October 30, 2025, that extension lasts up to 540 days from the card’s expiration.8U.S. Citizenship and Immigration Services. Automatic Employment Authorization Document (EAD) Extension DHS ended automatic EAD extensions for most renewal applications filed on or after October 30, 2025. Where an extension filed before that cutoff is still running, write “EAD EXT” and the automatic extension date in the Additional Information field of Section 2.9U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 5.1 Automatic Extensions Based on a Timely Filed Application to Renew Employment Authorization
Temporary Protected Status extensions work similarly. When the government extends TPS for a country, a Federal Register Notice typically extends the expiration date on associated TPS-related EADs automatically. For current employees, note “EAD EXT” and the new automatic extension date from the Federal Register Notice in the Additional Information field in Section 2.10U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 5.3 Automatic EAD Extensions for Temporary Protected Status (TPS) Beneficiaries Reverify once the automatic extension ends. The USCIS TPS page for each country links to the relevant notice with exact dates.
Discrimination Pitfalls to Avoid
This is where employers get into trouble most often, and the mistakes usually come from being too careful rather than too careless. Federal law prohibits document abuse: you cannot tell an employee which specific document to show, request more documents than necessary, or reject documents that reasonably appear genuine.11U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – Avoiding Discrimination in Recruiting, Hiring, and the Form I-9 Process
In practice, that means letting the employee choose the document. If someone presented an EAD at initial hire, you cannot demand another EAD for reverification; they can present any unexpired List A or List C document. Never reverify a Permanent Resident Card, even if it has expired. Do not demand specific documents to run through E-Verify or in response to a mismatch. And do not refuse a document because it expires soon.
Employers who treat workers differently based on citizenship status or national origin during reverification face civil fines and potentially court-ordered back pay.12U.S. Citizenship and Immigration Services. Penalties Overchecking one group of employees while waving others through is the exact pattern that draws discrimination complaints.
E-Verify and Rehires
If you use E-Verify and rehire a former employee within three years whose original I-9 already produced an “employment authorized” result, you generally do not create a new E-Verify case. Record the rehire date on Supplement B and move on.13E-Verify. E-Verify User Manual 2.0 – 2.1.2 Rehires That holds even if a List A or List C document requiring reverification has expired, as long as you update the document information on Supplement B. Reverifications never get a new E-Verify case.
Recordkeeping and Inspections
Attach the completed Supplement B to the employee’s original Form I-9, whether you keep records on paper or electronically. You must retain each Form I-9 for three years after the date of hire or one year after employment ends, whichever is later.14U.S. Citizenship and Immigration Services. Handbook for Employers M-274 – 10.0 Retaining Form I-9
When DHS, the Department of Justice, or the Department of Labor asks for your I-9 records, you have at least three business days to produce them.15U.S. Immigration and Customs Enforcement. Form I-9 Inspection Under Immigration and Nationality Act Section 274A That is a tight window if records are scattered across offices. Electronic storage systems must meet federal technical standards, including controls against unauthorized changes, an indexing system, the ability to produce legible copies, and an audit trail of who accessed each form.1eCFR. 8 CFR 274a.2 – Verification of Identity and Employment Authorization
Penalties for Getting It Wrong
Paperwork violations, like failing to complete Supplement B on time or filling it out incorrectly, carry base civil penalties of $100 to $1,000 per individual. Knowingly hiring or continuing to employ an unauthorized worker starts at $250 to $2,000 per worker for a first offense, rises to $2,000 to $5,000 for a second order, and reaches $3,000 to $10,000 per worker after multiple prior orders.16Office of the Law Revision Counsel. 8 USC 1324a – Unlawful Employment of Aliens These base amounts are adjusted for inflation each year, so actual fines run higher. Document abuse draws separate civil fines, potential back pay awards, and possible debarment from government contracts.12U.S. Citizenship and Immigration Services. Penalties During an inspection, incomplete supplements, late reverifications, and inconsistent treatment of employees all add up.