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COVID-19: DHS announces flexibility in requirements related to Form I-9 compliance

  1. Original Date Announced

    March 20, 2020

    COVID-19: DHS announces that ICE will exercise prosecutorial discretion to defer the physical presence requirements for the Employment Eligibility Verification (Form I-9) until May 19, 2020. DHS also announces that any employers who were served notices of inspection (NOIs) in March 2020 and have not already responded will be granted an automatic extension for 60 days; at the end of 60 days, DHS will determine if an additional extension will be granted. [ID #990]

    DHS announces flexibility in requirements related to Form I-9 compliance
  2. Effective Date

    March 20, 2020
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  4. Biden Administration Action: Approved/Retained

    January 27, 2021

    ICE Announces Extension to I-9 Compliance Flexibility (January 2021 Extension)

    This Biden administration policy extends the Trump-era policy identified in this entry.

    On January 27, 2021, ICE announced that it will extend its Form I-9 compliance flexibility through March 31, 2021.

    View Document
  5. Biden Administration Action: Approved/Retained

    March 31, 2021

    2021.03.31 ICE announces extension, new employee guidance to I-9 compliance flexibility

    This Biden administration policy extends the Trump-era policy identified in this entry.

    On March 31, 2021, ICE announced that it will extend its Form I-9 compliance flexibility through May 31, 2021. The current extension also includes guidance for employees hired on or after April 1, 2021, and work exclusively in a remote setting due to COVID-19-related precautions.

    View Document
  6. Biden Administration Action: Approved/Retained

    May 26, 2021

    2021.05.26 ICE announces extension, new employee guidance to I-9 compliance flexibility

    This Biden administration policy extends the Trump-era policy identified in this entry.

    On May 26, 2021, ICE announced that it will extend its Form I-9 compliance flexibility through August 31, 2021. The current extension also includes guidance for employees hired on or after June 1, 2021, and work exclusively in a remote setting due to COVID-19-related precautions.

    View Document
  7. Biden Administration Action: Approved/Retained

    August 31, 2021

    2021.08.31 ICE Press Release Announcing Extension

    This Biden administration policy extends the Trump-era policy identified in this entry.

    On August 31, 2021, ICE announced that it will extend its Form I-9 compliance flexibility through December 31, 2021. The current extension also includes guidance for employees hired on or after April 1, 2021, and work exclusively in a remote setting due to COVID-19-related precautions.

    View Document
  8. Biden Administration Action: Approved/Retained

    December 15, 2021

    2021.12.15 ICE announces extension to I-9 compliance flexibility

    This Biden administration policy extends the Trump-era policy identified in this entry.

    On December 15, 2021, ICE announced that it will extend its Form I-9 compliance flexibility through April 30, 2022. The current extension will continue to apply the guidance previously issued for employees hired on or after April 1, 2021, and work exclusively in a remote setting due to COVID19-related precautions.

    View Document
  9. Biden Administration Action: Approved/Retained

    April 25, 2022

    2022.04.25 ICE announces extension to I-9 compliance flexibility

    This Biden administration policy extends the Trump-era policy identified in this entry.

    On April 25, 2022, ICE announced that it will extend its Form I-9 compliance flexibility through October 31, 2022. The current extension will continue to apply the guidance previously issued for employees hired on or after April 1, 2021, and work exclusively in a remote setting due to COVID-19 related precautions.

    View Document
  10. Biden Administration Action: Approved/Retained

    October 11, 2022

    ICE announces extension to I-9 compliance flexibility

    This Biden administration policy extends the Trump-era policy identified in this entry.

    On October 11, 2022, DHS announced it will extend its Form I-9 compliance flexibility until July 31, 2023 "due to the continued safety precautions related to COVID-19."

    View Document
  11. Biden Administration Action: Modified

    May 4, 2023

    2023.05.04 ICYMI: ICE Announces Employers Will Have 30 Days to Reach I-9 Compliance After COVID Flexibilities Sunset on July 31

    This Biden administration policy modifies the Trump-era policy identified in this entry.

    On May 4, 2023, DHS and ICE announced that employers will have 30 days to reach compliance with Form I-9 requirements after the COVID-19 flexibilities sunset on July 31, 2023. DHS encourages employers who have been using temporary flexibilities to plan ahead to ensure that all required physical inspection of identity and employment eligibility documents is completed by Aug. 30, 2023.

    View Document
  12. Biden Administration Action: Modified

    July 21, 2023

    2023.07.21 Final Rule: Optional Alternatives to the Physical Document Examination Associated with Employment Eligibility Verification (Form I-9)

    This Biden administration policy modifies the Trump-era policy identified in this entry.

    On July 21, 2023, DHS announced it will make permanent Form I-9 compliance options "to conduct verification electronically" for certain employers "who participate in E-Verify and are in good standing" with the agency. The rule goes into effect August 1, 2023, and it will apply to workers hired after the rule's effective date.

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Current Status

Fully in Effect

Most Recent Action

July 21, 2023 Action: Modified 2023.07.21 Final Rule: Optional Alternatives to the Physical Document Examination Associated with Employment Eligibility Verification (Form I-9)
January 27, 2021
Acted on by Biden Administration
March 31, 2021
Acted on by Biden Administration
May 26, 2021
Acted on by Biden Administration
August 31, 2021
Acted on by Biden Administration
December 15, 2021
Acted on by Biden Administration
April 25, 2022
Acted on by Biden Administration
October 11, 2022
Acted on by Biden Administration
May 4, 2023
Acted on by Biden Administration
July 21, 2023
Acted on by Biden Administration

Original Trump Policy Status

Status: Final/Actual
Subject Matter: Employment Verification
Agencies Affected: ICE

Associated or Derivative Policies

Pre Trump-Era Policies

  • In normal times, a new employee must present documentation to the employer from the List of Acceptable Documents (Form I-9 Instructions) that establishes identity and employment authorization. The employer is normally required to review the documents in the employee's physical presence and must accept the document(s) if the document(s) reasonably appears to be genuine and to relate to the employee.

    8 CFR § 274a.2 - Verification of identity and employment authorization

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