Remote I-9 verification: the DHS alternative procedure, step by step

The alternative procedure is the DHS-authorized way to examine Form I-9 documents without being in the same room as the employee. USCIS limits it to employers who participate in E-Verify in good standing, at their E-Verify hiring sites (USCIS, Remote Examination of Documents (Optional Alternative Procedure)). It is a standing option on the current form, not a temporary measure.

Nothing changes about which documents count. The employee still chooses one List A document, or a List B document plus a List C document, from the I-9 documents lists. What changes is the way you look at them: a copy first, then the original held up to a camera.

The procedure adds one duty that an in-person review does not have. You must keep a clear copy of the front and back of every document examined remotely, with the form (USCIS Handbook for Employers M-274, 4.1 Retaining Copies of Documents).

The employer runs it, through an HR coordinator or any staff member trained on the E-Verify tutorial. USCIS says new E-Verify enrollees and users complete a tutorial that includes fraudulent document awareness training (USCIS, Remote Examination of Documents (Optional Alternative Procedure)). The employee supplies the copies and joins the call; the documents themselves still come from their usual issuers, such as the State Department, USCIS or a state DMV.

1. Confirm the hiring site is enrolled in E-Verify and that you run E-Verify on every new hire there.
2. Send the remote hire the Form I-9, the lists of acceptable documents and a request for copies of the documents they choose.
3. Review the copies as soon as they arrive, then book the live video call.
4. Complete Section 2 and create the E-Verify case, keeping the copies with the form.

• Running the remote procedure at a site that is not enrolled in E-Verify.
• Accepting a document on the video call that differs from the copy sent in advance.
• Offering video review only to employees of a certain nationality or immigration status.
• Forgetting to tick the alternative procedure box, so an inspector reads the form as an in-person review.
• Copying only the front of a two-sided card such as a Permanent Resident Card.

USCIS defines an E-Verify employer in good standing as one that meets three conditions at once (USCIS, Remote Examination of Documents (Optional Alternative Procedure)). If any one is missing, the employer goes back to a physical examination.

• It is enrolled in E-Verify for every hiring site that uses the alternative procedure.
• It uses E-Verify to confirm the employment eligibility of its new hires in the United States.
• It complies with all the other rules of the E-Verify program.

USCIS lists the steps in order (USCIS, Remote Examination of Documents (Optional Alternative Procedure)). The employee transmits copies first, then presents the very same documents on the call.

1. Examine copies, front and back if two-sided, of the documents or acceptable receipt the employee chose, to see that they reasonably appear genuine and relate to the employee.
2. Hold a live video interaction where the employee presents the same originals sent in the first step. A live video interaction is a real-time call with picture and sound, not a recorded clip or a photo sent later.
3. Keep a clear and legible copy of every document, front and back if two-sided.
4. Mark the alternative procedure in the Additional Information field of Section 2.

Going remote does not stretch the calendar. The employee completes Section 1 by the first day of work for pay (USCIS Handbook for Employers M-274, 3.0 Completing Section 1). Section 2 remains due within three business days of the start date (USCIS Handbook for Employers M-274, 4.0 Completing Section 2). The E-Verify case follows the same pace: create it no later than the third business day after the employee starts work for pay (E-Verify, Verification Process).

Plan the video call for day one or two, so a blurry copy or a dropped connection still leaves room for a second try.

Use the 01/20/25 edition, or the 08/01/23 printing whose expiration date at the top of the page reads 05/31/2027; the printing that expired 07/31/2026 is no longer valid (USCIS, I-9, Employment Eligibility Verification). On either edition, tick the alternative procedure box in Section 2 (USCIS, Remote Examination of Documents (Optional Alternative Procedure)). Employers who used the older 10/21/2019 edition wrote “Alternative Procedure” in the Additional Information field instead (USCIS, Remote Examination of Documents (Optional Alternative Procedure)).

For a rehire or a reverification done remotely, tick the same box in Supplement B. Do not create a new E-Verify case for a reverification (USCIS, Remote Examination of Documents (Optional Alternative Procedure)).

If you offer the procedure at a site, offer it consistently to every employee there. USCIS allows one exception: you may offer it to remote hires only and keep physical examination for onsite and hybrid staff (USCIS, Remote Examination of Documents (Optional Alternative Procedure)). That choice must not be made for a discriminatory purpose, nor treat people differently by citizenship, immigration status or national origin (USCIS, Remote Examination of Documents (Optional Alternative Procedure)).

Write the choice down in a short HR policy, for example “remote review for fully remote hires at the Denver site”, so the practice is the same for every hire.

Store the copies with the form, on paper, electronically or both, for as long as you keep the form (USCIS, Remote Examination of Documents (Optional Alternative Procedure)). That period runs three years after the date of hire or one year after employment ends, whichever is later (8 CFR 274a.2, Verification of identity and employment authorization).

In a Form I-9 audit, you must make the copies available to the federal inspector (USCIS, Remote Examination of Documents (Optional Alternative Procedure)). Keep them apart from the general personnel file and limit who can open them, since they hold identity numbers.

• USCIS, Remote Examination of Documents (Optional Alternative Procedure): Eligibility, the four steps, the Section 2 and Supplement B checkboxes on the 08/01/2023 and 01/20/2025 editions, the remote-hires-only option and retention of copies.
• USCIS, I-9, Employment Eligibility Verification: Current edition 01/20/25; the 08/01/23 edition with a 05/31/2027 expiration may also be used; the 08/01/23 printing expiring 07/31/2026 was valid only to that date; the expiration date is at the top of the page.
• USCIS Handbook for Employers M-274, 3.0 Completing Section 1: Section 1 is completed no later than the first day of work for pay.
• USCIS Handbook for Employers M-274, 4.0 Completing Section 2: Section 2 is due within three business days; an authorized representative may examine documents; the employer cannot specify documents.
• USCIS Handbook for Employers M-274, 4.1 Retaining Copies of Documents: Employers using remote examination must keep copies of the front and back of all documents presented remotely with the Form I-9.
• E-Verify, Verification Process: Cases are created no later than the third business day after the employee starts work for pay.
• 8 CFR 274a.2, Verification of identity and employment authorization: Forms I-9 are kept three years after hire or one year after employment ends, whichever is later.