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.I-9 Process for Non E-Verify Legal Entities v1.9

.I-9 Process for Non E-Verify Legal Entities v1.9


E-Verify uses Form I-9 data to verify the employment eligibility of the newly hired employees. If the Legal Entity (Company/Business Unit) is not enrolled in E-Verify, the requirements to complete Form I-9 is slightly different. 

How are non E-Verify Legal Entities identified?

Since non E-Verify Legal Entities have no necessity to access E-Verify system, the DHS Client Setup is not required for them. The step to create DHS Client user ID and password to communicate with the USCIS E-Verify System is not needed.

How to fill Section 1 data for non-E-Verify Legal Entities?

In Smart Onboarding, New Hire fills Section 1 data only when I-9AutoFill property is set to OFF by the System Administrators in Product Preferences. For information on this property settings, please refer to I-9AutoFill page.

Enter Section 1 data as applicable to you. Providing Social Security Number is optional. If SSN is not available leave the filed blank.

Similarly, some of the other fields such as Middle Initial, Other Last Names Used, Apt. Number, Employee's Email Address, Employee's Telephone Number are optional. If you cannot provide information in any of theses fields, enter N/A. For details on optional fields, please refer Form I-9 Section 1 under New Hires Payroll and Taxes.

Form I-9 Section 1



How do non-E-Verify participating employers complete Section 2?

Non E-Verify participating employers have no changes in completing Section 2 activity. The employer must enter information for one document from List A OR one document from List B AND one document from List C. For acceptable documents list and procedure to complete Form I-9, please click here.

The only change is the availability of documents under List B when the New Hire is a minor or special placement individual. Special document options are provided under List B if minors or disabled individuals have no identity documents to present for Form I-9. Employers can complete Section 2 by choosing "Special Placement" / "Individual under Age 18" document titles under List B and a document from List C that establish their employment authorization.

Please check the below examples for the documents list:

"Individual under Age 18" document title doesn't show in List B

for non-E-Verify participating legal entities

"Individual under Age 18" document title shows in List B

for E-Verify participating Legal Entities



"Special Placement" document title doesn't show in List B

for non-E-Verify participating legal entities

"Special Placement" document title shows in List B

for E-verify participating legal entities



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