Researched by the I9AuditReady Research Team · Last Updated: April 2026

Remote I-9 Verification: How to Complete Form I-9 for Remote Employees (2026)

The standard Form I-9 process requires the employer to physically examine the employee's original identity and work authorization documents in person. For remote employees, this creates a logistical challenge. There are two compliant approaches — one available to all employers, one exclusively for E-Verify employers.

Method 1

Authorized Representative

Available to all employers. Designate anyone near the employee to physically examine documents and complete Section 2 on your behalf.

Method 2

DHS Alternative Procedure

E-Verify employers only. Examine documents remotely via live video call. Requires document copies and E-Verify enrollment.

Method 1: Authorized Representative Process

Any employer — regardless of E-Verify enrollment — can use the authorized representative process. This is the most widely used approach for remote I-9 verification.

Who Can Be an Authorized Representative?

Anyone 18 years or older can serve as an authorized representative. There are no restrictions on who you designate. Common choices include:

Notary public near the employee's location
Local attorney or HR professional
Coworker at a nearby office of the same company
Staffing agency representative in the employee's city
Family member or trusted neighbor (permitted, though not ideal)

The authorized representative does NOT need to be an attorney, notary, or licensed professional. Any trusted adult will do. In many states, however, notarization of the I-9 is not permitted — the authorized representative completes the I-9, not a notarial act.

How Liability Works

The employer remains fully liable for any errors or violations made by the authorized representative. If the authorized representative accepts an expired document, the employer is cited — not the representative. Train or brief your representative carefully before they complete the I-9.

Step-by-Step for Authorized Representative

1
Identify a trusted person near the employee to serve as your authorized representative.
2
Provide the representative with: a copy of the Lists of Acceptable Documents, instructions for completing Section 2, and a blank Form I-9 (or electronic access if using I9AuditReady).
3
Have the employee present original, unexpired identity and work authorization documents to the representative in person.
4
The representative physically examines the documents — they must appear genuine and relate to the employee.
5
The representative completes Section 2, entering document details and signing as the authorized representative. They should write their own name and title/role, then add 'on behalf of [Employer Name]' in the employer fields.
6
Return the completed Section 2 to the employer. File the I-9 in your records.

Method 2: DHS Alternative Procedure (E-Verify Employers Only)

As of August 1, 2023, employers enrolled in E-Verify may use the DHS-authorized alternative procedure to examine documents remotely via live video call. This is the only DHS-sanctioned method for a fully remote I-9 where no one physically examines the employee's documents.

Eligibility Requirement

The employer must be enrolled in E-Verify and in good standing at the time the employee is hired. Employers cannot enroll retroactively to use this procedure for hires already made. Employers must also be actively creating E-Verify cases for all employees.

Step-by-Step for DHS Alternative Procedure

1
The employee transmits a clear, readable front-and-back copy of their identity and work authorization documents to the employer by email, secure file transfer, or the employer's I-9 system.
2
The employer schedules a live video call with the employee. Note: a pre-recorded video is NOT acceptable — the review must be live and interactive.
3
During the call, the employee holds up each original document to the camera. The employer examines the document to verify it appears genuine, relates to the person, and matches the copies received.
4
The employer retains the copies of the documents transmitted. This is mandatory — not optional — under the alternative procedure.
5
The employer completes Section 2 on the Form I-9, checks the 'Alternative Procedure' checkbox, and enters the date of the video interaction.
6
The employer creates an E-Verify case within 3 business days of the employee's start date, as normal.

COVID-Era Flexibilities — What Expired

During the COVID-19 pandemic, DHS allowed employers to defer physical document examination for employees hired remotely (Form I-9 COVID-19 Flexibilities). This meant employers could examine document copies over email or fax rather than original documents in person.

COVID Flexibilities Ended August 30, 2023

The COVID-19 flexibility period ended August 30, 2023. All employees hired under those flexibilities required in-person physical document examination by that date (or use of the new DHS alternative procedure for E-Verify employers). The COVID flexibility no longer applies to any new hires. If your company relied on it for past remote hires without completing proper in-person examination, you may have unresolved compliance gaps.

Common Remote I-9 Mistakes

Using pre-recorded video instead of live video for DHS alternative procedure

A pre-recorded video submission by the employee is not acceptable. The document examination must be live and interactive — both parties must be present in real time.

Using DHS alternative procedure without active E-Verify enrollment

An employer who is not enrolled in E-Verify cannot use the alternative procedure. You must be enrolled before the employee starts, and you must create an E-Verify case for that employee.

Failing to retain document copies under the DHS alternative procedure

Under the alternative procedure, retaining document copies is mandatory. This is different from standard I-9 rules where copies are optional (unless using E-Verify for Section 2).

Holding the authorized representative liable for errors

The employer bears full legal liability for Section 2 errors — even when an authorized representative made the mistake. Do not assume the representative's error insulates you.

Not telling the authorized representative what NOT to request

An untrained authorized representative may inadvertently demand a specific document (e.g., a green card) or reject an unfamiliar document. Brief your representative on the Lists of Acceptable Documents and the rule against requesting specific documents.

Track remote hire deadlines automatically.

I9AuditReady flags incomplete remote verifications and tracks Section 2 deadlines for every hire, regardless of location.

Start Free — Track Remote Hire Deadlines

Frequently Asked Questions

Can I complete Form I-9 remotely for a new hire?

Yes, with the right process. All employers can use the authorized representative method: designate any person near the employee to physically examine the original documents and complete Section 2 on your behalf. Employers enrolled in E-Verify can additionally use the DHS alternative procedure — examining documents via live video call and retaining copies. Neither option removes the requirement to physically examine original documents; both just allow someone other than the employer to do it.

Who can be an authorized representative for remote I-9?

Any person 18 years or older can serve as an authorized representative to complete Section 2 of Form I-9. This can be a notary public, a local HR professional, an attorney, a coworker at the same office, a trusted neighbor, or anyone else the employer designates. The authorized representative acts on behalf of the employer and the employer remains fully liable for any errors.

What are the DHS alternative procedure requirements?

To use the DHS alternative procedure for remote I-9 verification: (1) the employer must be enrolled in E-Verify at the time of hire; (2) the employee must transmit clear, readable copies of their original documents; (3) the employer must conduct a live video interaction with the employee to examine the documents; (4) the employer must retain copies of all documents examined; (5) the employer must check the 'Alternative Procedure' checkbox in Section 2; and (6) the employer must create an E-Verify case within 3 business days as normal.

Did COVID-era remote verification flexibilities end?

Yes. The DHS COVID-19 temporary flexibility — which allowed employers to defer in-person document examination for remote employees — ended on August 30, 2023. Employers who used those flexibilities had until August 30, 2023 to conduct in-person physical document examination for affected employees, or to use the new DHS alternative procedure if enrolled in E-Verify. The COVID flexibility no longer applies to any new hires.

Do I need to retain document copies when using the DHS alternative procedure?

Yes. When using the DHS alternative procedure, retaining copies of the documents examined during the video call is required — it is a mandatory element of the procedure, not optional. These copies must be retained for the same period as the Form I-9 itself (the longer of 3 years from hire or 1 year after termination). This is different from the standard I-9 process, where retaining document copies is optional (unless using E-Verify, where it is required).

Related Resources

I9AuditReady provides employer compliance tools and research — not legal advice. Consult a qualified immigration attorney for advice specific to your situation.