What’s New with Form I-9 in 2025? SchulzLaw Blog April 4, 2025.

By C. Matthew Schulz

Key Changes 

In 2025, U.S. Citizenship and Immigration Services (USCIS) introduced several important updates to Form I-9, the mandatory employment eligibility verification form and related instructions. These changes, reflected in the Trump Administration's January 2025 revision of Form I-9 and the updated M-274 Handbook for Employers, are designed to streamline compliance and incorporate more flexible procedures—particularly for remote document verification.

What is Form I-9?

Form I-9 is required for all U.S. employers to verify the identity and employment authorization of individuals hired for employment in the U.S. Both employees and employers (or authorized representatives) must complete the form.

What Changed

The updates are partly a continuation of modernizations introduced in the 2023 revision, but this year’s version includes further refinements, new features, and improved clarity. Here’s what stands out:

Remote Document Examination (“Alternative Procedure”)

USCIS formalized the alternative procedure that allows qualifying employers to examine Form I-9 documents remotely. This procedure includes:

• A checkbox in Section 2 to indicate use of the alternative procedure.
• New retention requirements for video documentation or audit logs associated with remote verification.
• Inclusion in the M-274 handbook as new Section 4.5, with guidance throughout the handbook explaining how to implement this method properly​.

Supplement B Replaces Section 3

The old Section 3 for rehires and reverifications has been removed. It’s now a standalone “Supplement B”. The government says this change improves form usability and provides clearer instructions for reverification and rehire situations​.

New Lists of Acceptable Documents

The updated Lists A, B, and C now:

• Include additional receipts, particularly for Afghan and Ukrainian parolees.
• Feature redesigned I-551 Permanent Resident Cards and I-766 EADs, with image samples and explanations​.
• Clarify documentation for refugees, asylees, and F-1 students.

Terminology and Accessibility Updates

In addition, the government replaced “alien authorized to work” with the more inclusive “noncitizen authorized to work” and included more detailed instructions and common abbreviations in the Appendix.

Best Practices for Employers

To stay compliant, employers should:

• Always use the most current version of Form I-9;
• Train HR staff on new remote document verification rules;
• Review and revise internal I-9 policies to reflect the use of Supplement B; and
• Use USCIS’s Form I-9 Retention Calculator to determine how long to keep records.

Conclusion

For more detailed guidance, contact the author and visit: Form I-9 Central and the M-274 Handbook for Employers.