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    I-9 Policy Changes

    Employers are required to complete an employee’s Form I-9 within three days of their first day of work. 

    To account for the fact that many individuals cannot currently renew their driver’s licenses or state ID cards due to stay-at-home orders, the Department of Homeland Security (DHS) has issued a temporary policy to allow employers to accept expired List B documents when completing the Form I-9. 

    While some states have extended the expiration of driver’s licenses and state identification cards, which are common List B documents, others have not. The temporary policy addresses both situations.

    Procedure for Expired List B Documents That Have Not Been Extended by the Issuing Authority

    List B documents that expire on or after March 1, 2020, and have not been extended by the state, may be treated the same as if the employee presented a valid receipt for an acceptable document for Form I-9 purposes.

    If an employee presents their driver’s license that expired on or after March 1 and it was not extended by the state, employers should:

    • Record the documentation information in Section 2 under List B, as applicable; and
    • Enter “COVID-19” in the “Additional Information” field.

    Once the DHS ends this temporary policy, the employee will be required to provide a valid unexpired document within 90 days. 

    At that time, employers must include the following in the Section 2 “Additional Information” field:

    • Record the number and other required document information from the actual document presented; and
    • Initial and date the change.

    Procedure for List B Documents That Have Been Extended by the Issuing Authority

    If the employee’s List B identity document expired on or after March 1, 2020, and the issuing authority has extended the document expiration date because of COVID-19, the document is acceptable as a List B document for Form I-9 (not as a receipt) during the extension timeframe specified by the issuing authority. 

    In that case, the employer must:

    • Enter the document’s expiration date in Section 2; and
    • Enter “COVID-19 EXT” in the “Additional Information” field.

    Employers may also attach a copy of a webpage or other notice indicating that the issuing authority has extended the documents. Employers can confirm that their state has auto-extended the expiration date of state IDs and driver’s licenses by checking the state Motor Vehicle Administration or Department of Motor Vehicles website.

    The employee is not required to present a valid unexpired List B document later.

    Have Questions?

    Additional details on temporary I-9 policies from the Department of Homeland Security are available here.

    If you have any questions, please contact us at

    This information in this communication is general in nature, and is not intended, nor should it be construed, as legal, accounting, tax or other professional advice rendered by GreenSlate, LLC. The reader should contact his or her attorney, CPA, or tax professional prior to taking any action based upon this information.

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