Start with what never needs reverifying
Reverification is never required when these documents expire:
- U.S. passports and U.S. passport cards. An expired passport is a problem for travel. It is not a problem for your I-9.
- Permanent Resident Cards — green cards. This is the big one. The card expires; lawful permanent resident status does not. A green card holder whose card expired last year is exactly as authorized to work as they were the day you hired them.
- List B identity documents,such as a driver's license. List B establishes identity, and identity doesn't lapse.
Asking anyway is not a harmless bit of diligence. Demanding documents you have no legal basis to demand, or specifying which document an employee must produce, is document abuse under the anti-discrimination provisions of the INA, and it is enforced. The pattern that draws attention is an employer who reverifies green card holders and nobody else, because the practical effect is that lawful permanent residents get asked for paperwork that U.S. citizens never do.
The expensive good intention
Don't ask
A well-meaning HR calendar reminder to “re-check expiring green cards” is a discrimination claim with a scheduling system behind it. Delete the reminder.
Some employees will also have entered N/A in the expiration field in Section 1 because their authorization genuinely doesn't expire — asylees, refugees, and certain citizens of the Federated States of Micronesia, the Republic of the Marshall Islands, and Palau. No reverification for them either.
When you must
Reverification is required when an employee's employment authorization expires — not when a document happens to have a date on it. In practice that means temporary work authorization: an Employment Authorization Document, or a List A document tied to a status with an end date.
The deadline is unforgiving in its simplicity. You must reverify no later than the date the employment authorization expires. Not the following week, not at the next review cycle. An employee who works a day past expiry without valid reverification is an unauthorized employee, and continuing to employ them knowingly is a substantially worse category of violation than a paperwork error.
The employee picks the document, not you
At reverification the employee presents a document of their choosing that shows current employment authorization — anything from List A or List C, including an unrestricted Social Security card. It does not have to be the same document or even the same category they used originally.
Your role is to accept what's presented if it reasonably appears genuine and relates to the person. Saying “I need to see your new EAD” when they've offered something else on the list is the same document-abuse problem in a different costume. Present the list; let them choose.
One real complication worth knowing exists rather than guessing at: certain EAD renewal categories carry an automatic extension, so a card showing an expired face date can still be valid when paired with a Form I-797C receipt notice. The length of that automatic extension has been changed by DHS more than once, in both directions. Do not work from memory or from a blog post — including this one. Check the current period on USCIS I-9 Central at the moment you need it.
Where the record goes
Reverification is recorded on Supplement B, Reverification and Rehire— what used to be Section 3, which is why half the internet still calls it that. You complete one block of Supplement B and attach it to the employee's original Form I-9. You do not start a fresh I-9, and you do not overwrite the original.
Supplement B also handles rehires: an employee rehired within three years of the original I-9 date can generally be brought back on the existing form rather than a new one, assuming their authorization is still current or gets reverified at that point.
The part that's an operations problem, not a legal one
The rules above are not difficult. Missing the date is what actually happens, and it happens because expiration tracking lives in one person's head or one spreadsheet nobody inherited.
A workable system is unglamorous: a single list of employees with expiring authorization, a reminder at 120 days and again at 30, and one named owner. Give the employee real lead time, because renewal processing is outside their control and a late filing that isn't their fault still ends with you unable to keep them working. Start early enough that the automatic-extension question gets answered before it becomes urgent rather than during the week it expires.
And keep the tracking separate from anything that touches the employees who never need reverifying. If the same spreadsheet has a column for green card expiration dates, someone will eventually act on it.
If you're fixing old files
Internal I-9 audits are legitimate and encouraged, with two rules. Do the whole population or a genuinely neutral sample, never a subset that correlates with national origin. And correct rather than conceal: errors get lined through, corrected, initialed, and dated — never erased, never backdated, never replaced with a clean form that pretends the original didn't exist. A backdated I-9 turns a civil paperwork penalty into something much worse.
Penalties are assessed per form, which is why a policy-level mistake applied across 200 hires is the expensive kind. If that's what you've found, the next call is an immigration attorney, not a bigger spreadsheet.
Setting up verification for people you'll never meet in person is the other half of this: the remote I-9 verification process covers the E-Verify gate, the three-step video procedure, and the form edition that stops being valid after July 31, 2026. For confirming that a new hire is a real, verifiable person rather than a well-documented one, that's identity verification — a different job from the I-9, and one the I-9 was never designed to do.