Form I-9 requirements
Last update: May 10, 2024
The University of Washington employs only individuals authorized to work in the United States in compliance with the Immigration Reform and Control Act of 1986.
The Employment Eligibility Verification Form I-9 is used to verify the identity and employment authorization of citizens and noncitizens hired for employment in the United States. Employees who are unable to meet federal Form I-9 requirements cannot lawfully be employed.
Who must complete the Form I-9?
These requirements apply to all staff and student employees. Stipend recipients and certain contingent workers complete the Form I-9 because they may move into a UW paid position which would require an I-9.
New employees must complete Form I-9, Section 1: Employee Information and Attestation and present original document(s) that establish their identity and employment authorization within the following established timelines:
- First day of employment: New employees are required to complete Section 1 of the Form I-9 by the end of their first day of employment. “First day of employment” means the date the employee begins performing labor or services in return for wages or other compensation.
- Third day of employment: The new employee must present original work authorization documents to their I-9 coordinator or authorized representative within three (3) days of hire. Employees must not work or be paid if work authorization documents are not physically inspected by the end of the third day.
- Seventh day of employment: If the Form I-9 is not completed within seven (7) business days of hire; employment may be terminated.
Employees who are rehired more than three (3) years after completing the Form I-9 at the University will be considered a new employee for the purpose of Form I-9 compliance and will therefore be required to complete a new Form I-9.
Detailed instructions for completing the Form I-9 in Workday are outlined in the I-9 User Guide.
The employee and the hiring department are responsible for timely completion of the Form I-9
Hiring departments are expected to coordinate with the employee and I-9 coordinator when identifying the employee’s first day of employment.
Prior to the employee’s first day of paid work, the employee will receive Workday notifications to complete Form I-9, Section 1 along with other onboarding tasks. Section 1 may be completed as soon as the job offer has been extended and accepted.
When Section 1 has been completed by the employee, they will receive information about Section 2 and the acceptable documents they may present to their I-9 coordinator. The employee may choose which document(s) from the list they will present.
Physical review of work authorization documents is required
Physical review of documentation to complete Section 2 is required for all employees, including for remote workers. If physical review by UW staff is not feasible, completion by an authorized representative may be permissible. For more information, visit the I-9 coordinator guide.
Ensuring compliance
Form I-9 compliance is monitored through regular audits. Department I-9 coordinators, the employee’s manager, and the head of the hiring department will be contacted if an audit returns any noncompliance. The escalation and oversight process will be regularly reviewed to ensure the UW remains compliant with federal requirements. Failure to timely complete the Form I-9 can result in serious penalties.
Recent updates to the Form I-9
Effective October 21, 2023, the University transitioned to the new Form I-9 as required by US Citizenship and Immigration Services (USCIS). All Form I-9s that were incomplete or in process as of October 27, 2023, were cancelled and restarted on the new form.
Note, the University is not considered an E-Verify employer and therefore does not use the new “alternative procedure” to inspect work authorization documents. When completing Section 2, all I-9 coordinators should use caution to not check the form field which indicates that the alternative procedure was used to inspect documents.
Resources
US Citizenship & Immigration Services I-9, Employment Eligibility Verification