During the pandemic, employers that hired employees who worked exclusively in remote settings due to COVID-19 precautions were temporarily exempt from the in-person inspection requirements for documents presented in connection with Form I-9. Under these circumstances, it was permissible for employers to remotely inspect the documents (over video link, fax, or email), and they were instructed to note “COVID-19” until such time that the documents could be inspected in person. This would explain the anticipated delay in the physical inspection of the original documents. Once normal operations resumed, the employer was supposed to inspect the documents in person within three business days and make an additional notation of “documents physically presented and examined,” initial, and date. Remember, any time information is corrected or added after initial completion of Form I-9, it must be initialed and dated. All of this is coming to an end on July 31, 2023. No more remote inspections will be allowed. This means for new hires who work remotely, someone will need to examine their I-9 documents within three business days from the start of employment. But there’s more….

Any and all I-9s that were completed during the pandemic for remote workers must be updated — meaning physical, in-person inspection of original identity and work authorization documents and annotation of I-9s — no later than August 30, 2023. Notations should be made in Section 2’s Additional Information field. If the same person performs both the remote and subsequent physical inspections for a reverification, the notation can state, “COVID-19 documents physically examined,” initial, and date. If a different person performs the physical inspection, the same notation should be made, but that person should also write their full name and title, instead of their initials. The following link contains examples of the required notations.

Form I-9 Examples Related to Temporary COVID-19 Policies | USCIS