Important Updates
Important Updates
April 28, 2026 | United StatesUnited States: DHS Issues Interim Final Rule Further Implementing H.R. 1 Reconciliation Act of 2025
04/28/2026 | BelgiumEuropean Migration Network (EMN) Belgium Report: Labour Migration in Times of Labour Shortages in Belgium
April 28, 2026 | ThailandThailand: Mandatory Online Work Permit and Foreign Worker Registration System Forthcoming
April 28, 2026 | ThailandThailand: New Work Permit Submission Options for Companies Eligible for the Rapid Process
April 28, 2026 | CanadaThe New York Times: Have a Canadian Great-Great Grandparent? It Could Make You Canadian.
April 28, 2026 | United StatesUnited States: DHS Issues Interim Final Rule Further Implementing H.R. 1 Reconciliation Act of 2025
04/28/2026 | BelgiumEuropean Migration Network (EMN) Belgium Report: Labour Migration in Times of Labour Shortages in Belgium
April 28, 2026 | ThailandThailand: Mandatory Online Work Permit and Foreign Worker Registration System Forthcoming
April 28, 2026 | ThailandThailand: New Work Permit Submission Options for Companies Eligible for the Rapid Process
April 28, 2026 | CanadaThe New York Times: Have a Canadian Great-Great Grandparent? It Could Make You Canadian.
April 28, 2026 | United StatesUnited States: DHS Issues Interim Final Rule Further Implementing H.R. 1 Reconciliation Act of 2025
Subscribe
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsVietnamese ImmigrationView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • Vietnamese Immigration
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
  • Insights

DHS Announces Flexibility in I-9 Verification Requirements

March 20, 2020

insight-news-default

Country / Territory

  • United StatesUnited States

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

At a Glance

  • Where an employee is working remotely because of the COVID-19 emergency, the employer may inspect the employee’s identity and employment authorization documents virtually using remote technology when completing Section 2 of Form I-9, or when completing Section 3 for I-9 reverifications.
  • When normal operations resume, employers will need to physically inspect documents for any employee whose original documents were not physically examined by the Section 2 or Section 3 signer.
  • The interim COVID-19 measures may not be used where some employees are physically present at the work location.

The issue

The Department of Homeland Security has issued interim guidelines for remote I-9 verification during the COVID-19 emergency.

Employers with employees working remotely due to COVID-19 will not be required to review identity and employment authorization documents in the employee's physical presence until the emergency is over, DHS has announced. This accommodation is not permitted where employees are physically reporting to a work location.

The DHS remote guidelines are not mandatory. Employers may continue to follow standard Form I-9 procedures, including the use of agents to complete verification on the employer’s behalf.

The interim procedures will be in effect for 60 days, or until 3 days after the national emergency is over, whichever comes first.

What to do now: remote examination of documents

Employers who are eligible for and elect to use the interim guidelines will be able to inspect Section 2 documents remotely, by video, fax or email, and must retain copies of the documents. The ordinary timelines for I-9 completion remain in effect. Section 1 of the I-9 must be completed by the employee’s start date and section 2 must be completed within 3 business days of the new hire’s start date.

After the emergency is over

Once normal operations resume, employers will need to physically inspect documents for all employees onboarded and I-9'd remotely. Employers should enter "COVID-19" as the reason for the physical inspection delay in the Section 2 additional information field, once physical inspection takes place after normal operations resume. Once the documents have been physically inspected, the employer should add "documents physically examined" with the date of inspection to the Section 2 additional information field (or Section 3 in reverification situations). 

Employers are advised to talk to their Fragomen representative or a member of the firm’s Government Strategies and Compliance team to develop procedures for addressing I-9s completed using these relaxed procedures once normal operations resume.

Limitations on use of remote procedures

If any employees are physically present at a work location, the interim guidelines do not apply.  All standard Form I-9 procedures and timelines remain in effect. However, if new employees become subject to COVID-19 quarantine or lockdown protocols, DHS may accept the employer’s use of remote procedures, but will evaluate these scenarios on a case-by-case basis.

Using an agent to complete I-9 verification

Under standard Form I-9 verification procedures, employers may designate an authorized representative to act on their behalf to complete Section 2. The representative must physically examine the employee’s identity and employment authorization documents in the employee’s physical presence.

An authorized representative can be any person the employer designates to complete and sign the Form I-9 on their behalf, including a friend or family member of the employee. No formal agreement or designation between the representative and the employer is necessary.  However, the employer is liable for any I-9 violations made by the authorized representative.

Temporary hiatus in I-9 audits

DHS also announced that effective March 19, 2020 any employer that had received a Notice of Inspection in March 2020 that had not yet responded to the audit would be provided an automatic 60-day extension of time to respond.

This alert is for informational purposes only. If you have any questions, please contact the immigration professional with whom you work at Fragomen.

Country / Territory

  • United StatesUnited States

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Fragomen news

European Migration Network (EMN) Belgium Report: Labour Migration in Times of Labour Shortages in Belgium

Senior Counsel Jo Antoons, Senior Immigration Managers Manuela Birsan and Andreia Ghimis, Senior Manager Wout Van Doren, Associate Pauline Chomel and Immigration Supervisor Elisabeth Kamm contributed to the European Migration Network (EMN) Belgium report "Labour Migration in Times of Labour Shortages in Belgium."

Learn more

Work authorization

From Investment to EU Residence: Why Italy’s Investor Visa is Gaining Momentum

Manager Pierangelo D'Errico explores how Italy’s Investor Visa is emerging as a strategic alternative to diminishing EU golden visa programmes, offering high‑net‑worth individuals flexible residence rights, deferred investment timing, Schengen access and a structured—though not accelerated—pathway to long‑term EU residence.

Learn more

Media mentions

The New York Times: Have a Canadian Great-Great Grandparent? It Could Make You Canadian.

Partner Rick Lamanna discusses Canada’s expanded citizenship by descent rules extending eligibility to potentially millions of people worldwide with only distant ancestral ties.

Learn more

Awards

Fragomen features in Ibec’s Top 100 Companies Leading in Wellbeing Index 2026

Fragomen is recognised in Ibec’s Top 100 Companies Leading in Wellbeing Index 2026, highlighting its commitment to employee wellbeing and a supportive workplace culture.

Learn more

Work authorization

The UK Global Talent Visa as a Flexible Residence Option for High-Net-Worth Individuals

Senior Manager Alexander Hood and Senior Associate Lara Hannaway outline how the UK Global Talent visa is increasingly being used by internationally mobile individuals as a flexible UK residence option, examining who the route is designed for, the endorsement process and the sectors currently covered, including the new design route launching in July 2026.

Learn more

Work authorization

Ireland Immigrant Investor Programme: Is the “Golden Visa” Route Now Closed?

Senior Manager Samantha Arnold examines the closure of Ireland’s Immigrant Investor Programme and outlines the limited remaining options for high net worth individuals seeking Irish residence through approved investment and charitable donation routes.

Learn more

Video

May 2026 Visa Bulletin | #MobilityMinute

Partner Melissa Vasquez-Myers highlights key updates from the May 2026 Visa Bulletin, including a pause in employment-based advancement, continued movement in family-based categories and a warning of potential retrogression later this fiscal year.

Learn more

Awards

Citywealth Leaders List: Top 30 Immigration Advisors 2026 Recognises Four Fragomen Professionals

Partners Parisa Karaahmet, Raquel Liberman and Julia Onslow-Cole and Practice Leader Olga Nechita are recognised in Citywealth’s Top 30 Immigration Advisors 2026 for their leadership in advising high-net-worth individuals and families on global mobility and cross-border planning.

Learn more

Work authorization

Family Reunification in Switzerland: Key Scenarios, Requirements and Risks

Manager Quentin Pache outlines the main family reunification pathways available in Switzerland, highlighting key eligibility requirements, procedural deadlines and practical risks that frequently lead to delays or refusals. 

Learn more

Media mentions

The Sunday Times: How to Make Your Move from the UK to the NetherlandsLearn more

Brexit

UK–EU Youth Mobility: Progress, Trade-offs and the Reality of Agreement

UK Government Affairs Strategy Director Shuyeb Muquit explains how a possible UK–EU Youth Mobility Scheme could work in practice, what challenges remain and what it may mean for young people and employers.

Learn more

Awards

12 Fragomen Lawyers Named to 2026 Pro Bono Recognition List

Twelve Fragomen lawyers are recognized on the 2026 Pro Bono Recognition List, reflecting their commitment to providing free legal assistance to those in need.

Learn more

Fragomen news

European Migration Network (EMN) Belgium Report: Labour Migration in Times of Labour Shortages in Belgium

Senior Counsel Jo Antoons, Senior Immigration Managers Manuela Birsan and Andreia Ghimis, Senior Manager Wout Van Doren, Associate Pauline Chomel and Immigration Supervisor Elisabeth Kamm contributed to the European Migration Network (EMN) Belgium report "Labour Migration in Times of Labour Shortages in Belgium."

Learn more

Work authorization

From Investment to EU Residence: Why Italy’s Investor Visa is Gaining Momentum

Manager Pierangelo D'Errico explores how Italy’s Investor Visa is emerging as a strategic alternative to diminishing EU golden visa programmes, offering high‑net‑worth individuals flexible residence rights, deferred investment timing, Schengen access and a structured—though not accelerated—pathway to long‑term EU residence.

Learn more

Media mentions

The New York Times: Have a Canadian Great-Great Grandparent? It Could Make You Canadian.

Partner Rick Lamanna discusses Canada’s expanded citizenship by descent rules extending eligibility to potentially millions of people worldwide with only distant ancestral ties.

Learn more

Awards

Fragomen features in Ibec’s Top 100 Companies Leading in Wellbeing Index 2026

Fragomen is recognised in Ibec’s Top 100 Companies Leading in Wellbeing Index 2026, highlighting its commitment to employee wellbeing and a supportive workplace culture.

Learn more

Work authorization

The UK Global Talent Visa as a Flexible Residence Option for High-Net-Worth Individuals

Senior Manager Alexander Hood and Senior Associate Lara Hannaway outline how the UK Global Talent visa is increasingly being used by internationally mobile individuals as a flexible UK residence option, examining who the route is designed for, the endorsement process and the sectors currently covered, including the new design route launching in July 2026.

Learn more

Work authorization

Ireland Immigrant Investor Programme: Is the “Golden Visa” Route Now Closed?

Senior Manager Samantha Arnold examines the closure of Ireland’s Immigrant Investor Programme and outlines the limited remaining options for high net worth individuals seeking Irish residence through approved investment and charitable donation routes.

Learn more

Video

May 2026 Visa Bulletin | #MobilityMinute

Partner Melissa Vasquez-Myers highlights key updates from the May 2026 Visa Bulletin, including a pause in employment-based advancement, continued movement in family-based categories and a warning of potential retrogression later this fiscal year.

Learn more

Awards

Citywealth Leaders List: Top 30 Immigration Advisors 2026 Recognises Four Fragomen Professionals

Partners Parisa Karaahmet, Raquel Liberman and Julia Onslow-Cole and Practice Leader Olga Nechita are recognised in Citywealth’s Top 30 Immigration Advisors 2026 for their leadership in advising high-net-worth individuals and families on global mobility and cross-border planning.

Learn more

Work authorization

Family Reunification in Switzerland: Key Scenarios, Requirements and Risks

Manager Quentin Pache outlines the main family reunification pathways available in Switzerland, highlighting key eligibility requirements, procedural deadlines and practical risks that frequently lead to delays or refusals. 

Learn more

Media mentions

The Sunday Times: How to Make Your Move from the UK to the NetherlandsLearn more

Brexit

UK–EU Youth Mobility: Progress, Trade-offs and the Reality of Agreement

UK Government Affairs Strategy Director Shuyeb Muquit explains how a possible UK–EU Youth Mobility Scheme could work in practice, what challenges remain and what it may mean for young people and employers.

Learn more

Awards

12 Fragomen Lawyers Named to 2026 Pro Bono Recognition List

Twelve Fragomen lawyers are recognized on the 2026 Pro Bono Recognition List, reflecting their commitment to providing free legal assistance to those in need.

Learn more

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.