Reverification is the deadline employers miss most, because nothing prompts it. Nobody applies for a job. No offer letter goes out. A document quietly expires and the form goes out of compliance on its own.
Supplement B replaced Section 3
On the current Form I-9, reverification and rehire are documented on Supplement B, Reverification and Rehire. This replaced what everyone used to call Section 3 as of August 2023. If your internal process still says “complete Section 3,” the wording is out of date even if the underlying steps are the same.
Also confirm you are working from the right form. Since August 1, 2026, employers must use the edition showing the 05/31/2027 expiration date.
When reverification is required
You must reverify before an employee’s temporary employment authorization expires. The rule is about the expiration of employment authorization, not the expiration of any document in the file.
When it is not required, and this is where people go wrong
Never reverify a U.S. citizen or a noncitizen national. Their status does not expire.
Do not reverify a lawful permanent resident. A green card can expire while permanent residence does not. A Permanent Resident Card bearing a USCIS-issued extension sticker is a valid List A document, and you should not reverify that employee.
Do not reverify List B identity documents. An expired driver license does not trigger anything. Identity documents are not employment authorization.
A foreign passport does not trigger reverification. It establishes identity. When a List A combination includes a passport with an I-94 and an I-20, reverification is driven by the document with the earlier end date, and the group is treated together rather than reverified each time one piece expires.
Reverifying someone you should not is not a harmless extra step. Demanding documents you are not entitled to ask for can be an unfair immigration-related employment practice.
We act as your authorized representative and complete Section 2 in person anywhere in the five boroughs, which works for any employer. If your company is enrolled in E-Verify, we can also complete it by live video nationwide. Same-day signed PDF, from $65 per employee.
What the employee gets to choose
The employee presents any unexpired document of their choosing from List A or List C. Not List B, because identity is already established. You may not tell them which document to bring, and you may not ask for a specific one.
They may re-present the same document they used originally if it is still valid. Record the document title, number and expiration date on Supplement B, then sign and date it.
Rehires
Supplement B also covers rehiring a former employee within three years of the date their original I-9 was completed. You may either complete Supplement B on the existing form or start a new one. If you use the existing form, confirm the information is still accurate and reverify if their authorization has since expired.
Do not let it come as a surprise
The employee’s authorization expiration is recorded in Section 1. Build a calendar reminder at ninety days out and again at thirty. The form must be updated before the expiration date, not in the week after somebody notices.
A lapsed reverification is not a filing you can quietly catch up on. Continuing to employ someone whose authorization has expired carries penalties far heavier than paperwork fines.
Receipts
If an employee presents a receipt for a replacement of a lost, stolen or damaged document, the ninety-day validity period runs from the date reverification was required, meaning the date the document or authorization expired. Not from the day they handed you the receipt.
Who can complete Supplement B
The same rules that govern Section 2 apply. Either the employer or a designated authorized representative examines the document. Physical examination in person is available to everyone; live video review is limited to employers enrolled in E-Verify following the DHS alternative procedure, and the alternative procedure box on Supplement B has to be checked. As of March 2026, failing to check that box is a substantive violation with no cure period.
Frequently asked questions
Does an expired green card require reverification?
No. Do not reverify lawful permanent residents.
Does an expired driver license require reverification?
No. List B documents establish identity, not work authorization.
Can I ask which document they plan to bring?
You can tell them it must come from List A or List C. You cannot request a specific document or reject an acceptable one.
What if I miss the deadline?
Stop and get advice. Continuing to employ someone without current authorization is a far more serious violation than a late form.
What does reverification cost with you?
Our reverification service is $45 per employee.
Calendar it, because nothing else will
Reverification has no trigger. Nobody applies, no offer letter goes out, and no system prompts you. A document quietly expires and the form falls out of compliance on its own.
The expiration date is recorded in Section 1. Put a reminder at 90 days and again at 30 days before it, and treat the 90 day one as the working deadline. Employees frequently need time to obtain a renewed document, and the reverification must be completed before the authorization lapses, not in the week somebody notices.
Automatic extensions
Certain Employment Authorization Documents receive automatic extensions in defined circumstances, which means the printed expiration date on the card is not always the operative date. Where an extension applies, the employee may present the expired card together with the appropriate notice as evidence of continued authorization.
The rules change, so confirm the current position with USCIS rather than relying on what applied last year. Getting this wrong in either direction is costly: terminating somebody who is authorized, or continuing to employ somebody who is not.
What happens if you miss it
Stop and get advice. Continuing to employ a person whose authorization has lapsed is a substantive violation, and it carries penalties far heavier than a paperwork fine. First offence knowing hire penalties run from $716 to $5,724 per worker and escalate from there.
Do not backdate anything. Complete the reverification as soon as you discover it, attach a signed and dated explanation of the corrective action, and speak to immigration counsel about the gap.
Rehires use the same supplement
Supplement B covers two events, and the second gets forgotten. If a former employee returns to work within three years of the date their original Form I-9 was completed, you may use Supplement B on the existing form rather than starting a new one.
Confirm the information is still accurate, record the rehire date, and reverify if their work authorization has expired in the meantime. Beyond three years, complete a new form.
Whether to reuse or restart is a judgement call. A form that was correct and complete is worth reusing. A form with defects is worth replacing, because reusing it carries the old errors forward into a document you are certifying again today.
Correcting Supplement B
Mistakes are corrected the same way as elsewhere on the form. Draw a single line through the incorrect entry, write the correct information, then initial and date the change.
Never use correction fluid, never erase, and never backdate. An employer may correct Section 2 and Supplement B but may not correct Section 1, which belongs to the employee. If the section contains several errors, complete a fresh Supplement B, attach it to the original form, and add a signed and dated explanation of what changed and why.
Related reading
- I-9 acceptable documents: List A, B and C
- I-9 verification for H-1B workers and remote hires
- I-9 audits and ICE Notices of Inspection
- E-Verify vs Form I-9
- I-9 verification service in NYC
This is general information, not legal advice, and NotarEaseNYC is not a law firm. Federal I-9 rules and penalty amounts change. Confirm current requirements with USCIS, ICE, or qualified immigration counsel before relying on this.