Understanding Document Requirements for Form I-9 and Identity Verification

Applies to: US W-2 employees. Form I-9 is an employment requirement, so independent contractors, Canadian T4 employees and international workers do not complete one and will not see this step.

Federal law requires employers to verify the identity and employment authorization of individuals hired to work in the United States. This process is completed using Form I-9, Employment Eligibility Verification, and, when applicable, E-Verify.

Choosing the correct documents—and entering the correct information from those documents—helps prevent delays in onboarding and employment eligibility verification.

Understanding Lists A, B, and C

The Form I-9 Lists of Acceptable Documents are divided into three categories:

• List A documents establish both identity and employment authorization.

• List B documents establish identity only.

• List C documents establish employment authorization only.

To complete Form I-9, you may generally provide either:

• One acceptable List A document; OR

• One acceptable List B document AND one acceptable List C document.

For example, an unexpired U.S. passport is generally a List A document and can satisfy both requirements by itself. Alternatively, an employee might provide a driver's license from List B along with an unrestricted Social Security card from List C.

You may choose which acceptable document or combination of documents you want to provide. Employers generally may not require you to provide a particular Form I-9 document as long as the documents you select are acceptable under Form I-9 requirements.

Important: List B Documents Must Include a Photo for E-Verify

Because Ascen participates in E-Verify, any document presented from List B must contain a photograph.

This is an additional E-Verify requirement. Although the Form I-9 Lists of Acceptable Documents include some List B documents that may not normally contain a photograph, those documents cannot be accepted for an E-Verify case unless they contain a photo.

For example, a voter registration card may normally qualify as a List B document for Form I-9. However, if it does not contain a photograph, an E-Verify employer cannot accept it as the employee's List B document.

This photo requirement also applies to employees who are under age 18 and employees with disabilities.

Common List B Examples

Depending on the document and issuing authority, acceptable List B documents may include:

• Driver's license or identification card issued by a state or U.S. territory

• Federal, state, or local government identification card

• School identification card

• Voter registration card

• U.S. military card or draft record

For E-Verify purposes, the List B document you provide must contain your photograph.

Social Security Card: Which Number Should I Use?

A Social Security card may contain more than one number, which can sometimes cause confusion.

Your Social Security Number (SSN) is the nine-digit number printed on the front of the card. This is the number that should be used when your SSN is requested for Form I-9, E-Verify, payroll, or other employment documentation.

The number printed on the back of the Social Security card is not your SSN. It is a control number used by the Social Security Administration for card production and tracking purposes.

Always enter the nine-digit SSN shown on the front of the card.

Because Ascen participates in E-Verify, employees are also required to provide their Social Security number in Section 1 of Form I-9.

Are All Social Security Cards Acceptable for Form I-9?

No. Only an unrestricted Social Security card may generally be used as a List C document.

A Social Security card is not acceptable as a List C document if it contains language restricting its use for employment, including:

• "VALID FOR WORK ONLY WITH DHS AUTHORIZATION"

• "VALID FOR WORK ONLY WITH INS AUTHORIZATION"

• "NOT VALID FOR EMPLOYMENT"

A card marked "VALID FOR WORK ONLY WITH DHS AUTHORIZATION" indicates that separate Department of Homeland Security authorization is required for employment. The Social Security card itself therefore cannot establish employment authorization for Form I-9 purposes.

If you have a restricted Social Security card, you will need to provide another acceptable Form I-9 document or combination of documents.

For example, depending on your circumstances, you may be able to provide:

• An acceptable List A document, such as a valid Employment Authorization Document (Form I-766); or

• Another acceptable List B + List C combination for which you are eligible.

A restricted Social Security card may still be usable for other identity or administrative processes, but acceptance for those purposes does not make it acceptable as a List C Form I-9 document.

Can I Use My Employment Authorization Document (EAD)?

A valid Employment Authorization Document, Form I-766, is a List A document.

Because it establishes both identity and employment authorization, an acceptable EAD may generally be presented by itself without also providing a List B or List C document.

If your EAD has expired, additional rules may apply if DHS or USCIS has automatically extended the validity of the document. Eligibility for an automatic extension depends on your specific immigration category, filing circumstances, and applicable DHS guidance.

Do not assume that an expired EAD is automatically acceptable. Additional documentation may be necessary to establish that an extension applies.

Can I Use an Expired Document?

Generally, Form I-9 documents must be unexpired when presented, unless a specific law, regulation, or Department of Homeland Security announcement provides that the document's validity has been extended.

For example, certain EADs may remain valid beyond the expiration date printed on the card when the employee qualifies for an authorized automatic extension.

If you believe your document has been automatically extended, provide the document and any applicable supporting documentation so that its eligibility can be reviewed.

What If My Document Was Lost, Stolen, or Damaged?

Form I-9 rules allow certain receipts to temporarily satisfy documentation requirements.

One common example is when an acceptable Form I-9 document was lost, stolen, or damaged and you have applied for a replacement. In qualifying circumstances, the receipt showing that you applied for the replacement may be temporarily acceptable.

The actual replacement document generally must then be provided within the applicable Form I-9 receipt period.

Importantly, a receipt showing that you have simply applied for an initial document or a renewal document is generally not the same as a receipt for replacement of a lost, stolen, or damaged document and may not satisfy Form I-9 requirements unless another specific rule applies.

Can I Use a Birth Certificate?

Certain birth certificates may qualify as List C documents.

Generally, the document must be an original or certified copy of a birth certificate issued by a state, county, municipal authority, or territory of the United States bearing an official seal, as described on the current Form I-9 Lists of Acceptable Documents.

Because a birth certificate establishes employment authorization rather than identity, it must generally be paired with an acceptable List B identity document.

Because Ascen participates in E-Verify, that List B document must contain a photograph.

Can I Use a Hospital Birth Certificate?

Hospital-issued birth records or keepsake certificates are generally not the same as a government-issued certified birth certificate for Form I-9 purposes.

If you plan to use a birth certificate as your List C document, make sure it is an acceptable government-issued original or certified copy rather than a hospital souvenir or informational record.

Can I Use a School ID?

A school identification card can be a List B document when it otherwise satisfies the Form I-9 requirements.

However, because Ascen participates in E-Verify, the school ID must contain your photograph.

A school ID without a photo cannot be accepted as your List B document for an E-Verify case.

Can I Use a Passport?

An unexpired U.S. passport or U.S. passport card is generally a List A document and establishes both identity and employment authorization.

Because it is a List A document, you generally do not need to also provide a Social Security card, driver's license, or another List B/List C combination for Form I-9.

Different requirements apply to foreign passports. A foreign passport by itself does not automatically establish authorization to work in the United States and may need to be presented with other immigration documentation as specified on the Form I-9 Lists of Acceptable Documents.

What If My Name Is Different Across My Documents?

Your Form I-9 should generally reflect your current legal name.

If the name on one of your documents differs from the name entered on Form I-9—for example, because of marriage, divorce, adoption, or another legal name change—the discrepancy may need to be reviewed before verification can be completed. As a general rule, the name that you have on file with the Social Security Administration is considered your legal name.

Small formatting differences do not necessarily mean that a document is unacceptable, but significant discrepancies may require additional clarification.

Make sure the information you enter during onboarding is accurate and matches your legal records whenever possible.

Do I Have to Provide a Social Security Card?

Not necessarily for Form I-9 documentation.

An employee completing Form I-9 generally chooses which acceptable documents to present. If you provide a valid List A document, for example, you generally do not also need to present your Social Security card as a Form I-9 document.

However, because Ascen participates in E-Verify, you must provide your Social Security number in Section 1 of Form I-9. Providing your SSN does not necessarily mean that you must present your physical Social Security card as your Form I-9 document.

A Social Security card may also be requested separately for payroll, tax, or another administrative process when permitted.

Does My Form I-9 Document Have to Match the Document I Used for Identity Verification?

Not necessarily.

An onboarding platform may include an identity verification or fraud-prevention step that is separate from Form I-9.

A document being accepted for identity verification does not automatically mean that the same document is acceptable for Form I-9, and vice versa.

For example, a restricted Social Security card may potentially be used in another administrative verification process but cannot be used as a List C Form I-9 document.

Always follow the requirements shown specifically for the Form I-9 step of onboarding.

Do I Need to Provide Three Documents?

No.

In most situations, providing additional documents is unnecessary.

You generally need either:

Option 1:
One acceptable document from List A

OR

Option 2:
One acceptable document from List B
+
One acceptable document from List C

Employers generally should not request additional Form I-9 documents once you have presented documentation that appropriately satisfies the Form I-9 requirements.

What If the System Rejects or Flags My Document?

A document upload or verification issue does not necessarily mean that you are not authorized to work.

Common causes of delays may include:

• Selecting the wrong document type

• Entering the wrong document number

• Entering the Social Security card control number instead of the SSN

• Uploading a restricted Social Security card as a List C document

• Providing a List B document without a photograph

• Providing an expired document that does not qualify for an extension

• Providing an unclear, incomplete, or unreadable image

• Entering a name, date of birth, document number, or other information that does not match the document

• Providing documentation that is acceptable for another onboarding requirement but not acceptable for Form I-9

If additional documentation or clarification is requested, carefully review the request and provide documentation that addresses the specific issue identified.

Remember: You Choose Your Form I-9 Documents

You have the right to choose which acceptable Form I-9 documents you present.

Ascen cannot require you to provide a particular document—such as a passport, driver's license, Social Security card, or EAD—if you can provide another acceptable document or combination of documents that satisfies the Form I-9 requirements.

However, the documents you choose must meet all applicable Form I-9 and E-Verify requirements, including the requirement that a List B document contain a photograph when E-Verify is used.

Before Submitting Your Documents

To help avoid onboarding delays:

• Confirm that you are providing either one List A document or one List B + one List C document.

• If providing a List B document, make sure it contains your photograph.

• Confirm that your documents are unexpired unless a specific extension applies.

• If using a Social Security card as List C, confirm that it does not contain an employment restriction.

• Enter the SSN from the front of your Social Security card, not the control number on the back.

• Make sure document numbers, names, and expiration dates are entered exactly as shown on the applicable document.

• Upload clear and complete images when document images are required.

• Review the current Form I-9 Lists of Acceptable Documents if you are unsure which documents you may provide.

Form I-9 and E-Verify requirements are established by the U.S. Department of Homeland Security and may change. The current Form I-9 instructions and Lists of Acceptable Documents should always be used when determining whether documentation is acceptable.

Still Having Trouble?

If you continue to experience issues completing Form I-9 or the identity verification process — such as errors submitting the form, 404 errors, or being unable to proceed in the onboarding portal — please contact your HR administrator or reach out to support for assistance.