A missed reverification is a fineable I-9 violation — treated the same as a substantive paperwork error, at $288–$2,861 per form under the 2026 civil penalty schedule. This tracker turns an expiration-date spreadsheet into an actionable deadline list before any date slips past.
Who needs reverification: employees with time-limited work authorization — typically EAD holders, H-1B / L-1 / TN workers, OPT/STEM OPT students, and anyone whose List A or C document carries an expiration date tied to their underlying work authorization. You do not reverify U.S. citizens, permanent residents, or List B documents (driver's licenses). See the full reverification guide for edge cases.
This tracker is a point-in-time snapshot. Or start with a free single-form I-9 audit if you want to check your underlying I-9 for errors first.
Informational tool only — not legal advice. Reverification rules depend on immigration status, document type, and DHS guidance that can change. FreshVerdict is a software tool, not a law firm.
How reverification deadlines work
The clock runs on the employee's work authorization, not just the document. When an EAD, I-94, or OPT period expires, the employer must complete Supplement B reverification on or before that date — after inspecting a new valid work-authorization document. DHS expects employers to have a system that catches these dates in advance; an after-the-fact fix is still citable.
The 90-day rule applies to receipt notices: if an employee presents a receipt for a renewal of a List A or C document, you have 90 days to obtain and inspect the actual renewed document. That 90-day window is a separate reverification deadline and should be tracked alongside document-expiration dates.
Reverification is always on Supplement B of the current Form I-9 edition. Never use an outdated form version for reverification; using a withdrawn edition can itself be flagged. Record the date you actually examined the new document — never backdate to the old expiration date or the document's issue date.
Track deadlines automatically — not manually.
FreshVerdict's reverification monitoring watches every expiration date in your I-9 file and alerts you well before each deadline — so a Supplement B never slips because a date fell off a spreadsheet. Start at $29/mo, cancel anytime.
Start reverification monitoring →I-9 reverification FAQ
When do I need to reverify an employee's I-9?
Reverification is required when an employee's work authorization expires — not just the document, but the underlying authorization. Common triggers: an expiring Employment Authorization Document (EAD), an H-1B or L-1 I-94 expiration date, OPT or STEM OPT expiration, or a 90-day receipt notice window closing. The key rule: reverification must happen on or before the expiration date, not after.
What form do I use to reverify an I-9?
You complete Supplement B of the current Form I-9 edition on the employee's existing I-9. Do not start a new I-9 unless Supplement B is already filled (from a prior reverification or a prior name-change entry). Record the new document title, issuing authority, document number, and expiration date. Date the entry the day you actually re-examine the document — never backdate to the old expiration date or the document's issue date.
Do I have to reverify a green card (lawful permanent resident)?
No. Lawful permanent residents' underlying status does not expire even when the physical green card card does. You must NOT reverify a green card. Demanding a new card as a reverification step can constitute immigration-related discrimination under IER rules. The same rule applies to U.S. citizens and nationals — their status never expires.
Do I reverify a driver's license or other List B document?
Never. List B documents (driver's licenses, state IDs) are never reverified, even if they expire. Writing in Supplement B for a List B document is itself an I-9 error. Reverification only applies to List A or List C documents that have an expiration date tied to work authorization.
Related: I-9 reverification guide 2026 (complete rules, edge cases, the five mistakes that create new violations) · I-9 self-audit checklist 2026 (fix every error type) · I-9 penalty calculator (estimate your fine exposure from the full I-9 file) · I-9 civil penalties 2026.
FreshVerdict is an I-9 compliance tool — not attorneys, and this is general information, not legal advice. Reverification rules reflect 2026 DHS guidance. For complex nonimmigrant status scenarios (cap-gap, H-1B portability, STEM OPT), consult an immigration attorney.