What an I-9 authorized representative actually does.
Federal law requires every U.S. employer to verify the identity and work authorization of all employees hired after November 6, 1986. This is done using Form I-9, issued by USCIS under the Immigration Reform and Control Act (IRCA).
When you cannot be physically present to complete Section 2, you may designate an authorized representative under 8 CFR 274a.2 to act on your behalf. That representative must physically examine the employee’s original documents in person. USCIS does not permit remote or virtual examination of physical documents for Section 2 completion (except for E-Verify employers using the 2023 Alternative Procedure).
The I-9 form is not notarized. No notary seal is applied. We sign as your authorized representative, not as a notary public. This distinction is important both for legal accuracy and for how the completed form is reviewed during any ICE audit.
| Violation Type | Fine Range |
|---|---|
| Technical / paperwork error | $281–$2,789 |
| First-time unauthorized hire | $698–$5,579 |
| Second-time unauthorized hire | $5,579–$13,946 |
| Subsequent unauthorized hire | $8,369–$27,894 |
Source: DHS 2024 annual inflation adjustment. Fines apply per violation. We are not an immigration law firm.
Four types of employers who call us.
Any employer who cannot physically complete Section 2 at the employee’s location needs an authorized representative. These are the four situations we handle most.
Remote-first companies
Employers based outside Massachusetts hiring remote workers locally. We complete Section 2 at the employee’s home or nearest office. No need to fly HR staff in.
Multi-location businesses
Companies with satellite offices or job sites across the Merrimack Valley without dedicated HR staff on-site. We travel to the work location for each new hire.
Staffing agencies
Agencies placing workers across multiple client sites. We handle group I-9 sessions for new-hire cohorts and individual verifications for time-sensitive placements.
Small businesses
Local businesses that hire infrequently and need a reliable local resource for I-9 Section 2 completion without maintaining an in-house HR function.
Who completes what. And when.
The I-9 is a three-section form. Each section has a different owner and a different deadline. We handle Section 2 on your behalf.
The employee provides their name, address, date of birth, immigration status and Social Security number (if required). They attest under penalty of perjury that they are authorized to work. This section is entirely the employee’s responsibility and must be complete before we begin Section 2.
We physically examine the employee’s original identity and work authorization documents from the USCIS acceptable document lists. We record the document title, issuing authority, document number and expiration date. We sign as your authorized representative. This is the section the employer legally owns — and the section where most violations occur.
Used when an employee’s work authorization expires or when rehiring a former employee within 3 years of their original I-9 date. The employer completes this section internally when reverification is needed. We do not handle Section 3 as part of our standard service. Ask us if you need assistance scheduling a Section 3 update.
What the employee must bring.
The employee must present original, unexpired documents. Photocopies are not acceptable. The employee chooses which documents to present — the employer and authorized representative cannot specify which documents to use.
- ✓ U.S. Passport or Passport Card
- ✓ Permanent Resident Card (Green Card)
- ✓ Employment Authorization Document
- ✓ Foreign passport with I-94 or I-551 stamp
Presenting a List A document alone satisfies all Section 2 requirements.
- ✓ State driver’s license
- ✓ State ID card
- ✓ School ID with photo
- ✓ Military ID or draft record
A List B document must be paired with a List C document.
- ✓ U.S. Social Security card
- ✓ Certification of Birth Abroad
- ✓ U.S. Birth Certificate
- ✓ Native American tribal document
For full lists, see uscis.gov.
Four things every employer needs to get right.
Accurate I-9 records are not optional. ICE can audit any employer at any time without notice. These four areas account for the majority of penalty-triggering violations.
Complete within 3 business days
Section 2 must be done within 3 business days of the hire date. For shorter-term hires, it must be done on day one. We offer same-day appointments to meet urgent deadlines.
Never accept photocopies
Only original, unexpired documents are acceptable. Expired documents, photocopies and digital images on a phone are not acceptable. We check every document in person.
Retain forms for the full period
Retain I-9 forms for 3 years from the date of hire OR 1 year after termination — whichever is later. Store separately from personnel files for easier audit access.
Conduct regular internal audits
Review I-9 forms periodically for completeness and accuracy. Reverify work authorization for employees whose authorization expires. Consult an employment attorney before correcting existing forms.
I-9 verification across the Merrimack Valley.
We travel to the employee’s location anywhere in the following towns. Group sessions available for employers with multiple new hires in one area.
Outside these towns? Call 978-424-4629. We quote all locations before accepting the assignment.
Reverification, receipts and rehires. The edge cases HR actually calls about.
Section 2 on day three is the routine part. The calls we get from HR teams are about everything around it: expiring work authorizations, lost documents, employees coming back after a year away, names no longer matching the file. Here is how the four most common edge cases work in practice, with the standing caution to run your specific facts past employment counsel, because the details below are process description rather than legal advice.
Reverification on Supplement B
When an employee’s employment authorization carries an expiration date, reverification is due before that date arrives. The current form handles this on Supplement B. For remote workers, we complete the document examination in person as your representative, following the instructions you send, and the employer tracks the calendar.
The receipt rule
An employee whose document was lost, stolen or damaged shows a receipt for its replacement instead. A qualifying receipt generally covers a limited window, and the replacement document must be examined when it arrives. Two meetings instead of one, so tell us upfront and we schedule both correctly.
Rehires
A seasonal worker or boomerang employee returning within three years raises a choice: rehire documentation on Supplement B or a fresh Form I-9, depending on the employer’s policy and counsel’s advice. Decide the path before booking, send the corresponding paperwork, and we complete whichever version you chose.
Name changes
An employee marries, divorces or legally changes a name, and the personnel file no longer matches the I-9. Employers commonly record the change on Supplement B. There is nuance in when this is required versus recommended, so this one especially belongs on counsel’s desk before the meeting, not after.
The thread connecting all four cases is calendar discipline. Nearly every edge-case penalty story starts with a date nobody was watching: an authorization expiring quietly, a receipt window closing, a rehire processed on instinct instead of policy. The employer owns the calendar, and counsel owns the policy. What we add is a consistent examiner on the ground, so a company with remote staff scattered across Tewksbury, Lowell, Andover and beyond gets every Section 2 and every Supplement B meeting handled the same careful way, by the same office, with the paperwork returned on the same predictable schedule. When an audit letter eventually arrives, uniform files are the difference between an afternoon of copying and a month of reconstruction, billed at attorney rates while the fine schedule waits in the background.
From offer letter to filed form. A worked timeline.
Abstract deadlines become concrete the moment a real start date lands on them. Here is the standard case worked through day by day, followed by the practical details of scheduling, billing and the questions employers ask before their first booking.
An employer in Austin hires a remote developer in Lowell. The offer is accepted on Wednesday, and the start date is the following Monday. Section 2 must be completed within three business days of that first day of work, which puts the true deadline at Thursday of the start week. The comfortable version of this timeline books us on Thursday or Friday before the start date: HR emails the instructions and the employee’s Section 1 link, the employee books a slot, brings original documents, and the completed form is back with the employer before the developer’s first standup. The stressful version calls us on the deadline day itself. We handle those too, same-day when slots allow, but the comfortable version costs nothing extra and removes the single point of failure. A start date is a celebration for the new hire and a countdown timer for HR, and the difference between the two versions is one email sent three days earlier.
Scheduling is plain. In-office appointments run Monday through Friday, 10 AM to 5 PM, by appointment at 1215 Main St, Unit 115, Tewksbury, inside the Neighborhood Parcel building with free parking. Mobile visits reach the employee’s home or job site across the Merrimack Valley, priced by zone. Most Section 2 meetings take 10 to 15 minutes once the documents are on the table: we examine the originals, complete and sign the employer’s form per the instructions provided, and return it the way the employer specifies, whether by secure upload to your HR platform, scan to a named inbox or tracked original by mail.
Multi-state employers should note what our role does and does not cover geographically. We handle employees located in our Massachusetts service area, the Merrimack Valley and the communities around it. A company onboarding one hire in Lowell and another in Phoenix needs a representative in each place, and most HR platforms that dispatch these requests understand that. What you get from us is the local half done reliably: a real office, a person who answers the phone, and Section 2 meetings completed the same way on the fifth hire as on the first. HR coordinators tell us the consistency is the point, since a patchwork of one-time representatives is where formatting drift creeps into I-9 files.
Billing is equally plain. Some employers pay directly, others have the employee pay and reimburse; tell us which when booking. We take credit, debit, Apple Pay, PayPal, Zelle and cash. For current rates, view current notary pricing or ask when you call, and you get the number before anything is scheduled. Staffing agencies and employers with recurring hires get the same predictable turnaround on every placement, one phone number, no re-explaining the process for each new hire.
Three questions come up before nearly every first booking, so here are the answers in advance. Can anyone act as the authorized representative, even the employee’s neighbor? Under the form instructions, yes, and the employer stays fully liable for every error that person makes, which is exactly why companies choose an experienced representative instead of a favor from a friend. Do we keep copies of the employee’s documents? We follow the employer’s written instructions on this, since copy retention is the employer’s policy decision, applied consistently or not at all. And what happens when a presented document is not on the Lists of Acceptable Documents, or does not reasonably appear to relate to the person standing in front of us? The meeting pauses, the employer is informed, and the employer decides the next step. We do not improvise around a document problem, because improvised fixes are what auditors find later.
Onboarding paperwork rarely travels alone. New hires often need a notarized CORI acknowledgment form in the same week, and HR teams building out compliance processes will find the small business notary guide a useful map of everything else a growing company ends up notarizing. When the hire is waiting and the deadline is math rather than opinion, schedule the appointment or call 978-424-4629 and we put the meeting on the calendar today, with the paperwork back in your system before the deadline stops being theoretical.
I-9 authorized representative questions, answered.
Do I need to notarize an I-9 form?
What is an I-9 authorized representative?
What documents does the employee need to bring?
How soon must Section 2 be completed?
Who is responsible if there is an error on the I-9?
Can you handle I-9 verification for a group of new hires?
Do you offer I-9 services on evenings and weekends?
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Learn moreWe act as the employer’s designated authorized representative under 8 CFR 274a.2. We do not notarize Form I-9 and no Massachusetts notary seal is applied. The employer designates us in this capacity and retains full legal responsibility for I-9 accuracy and compliance with all USCIS regulations.
We are not an immigration law firm and do not provide immigration advice, employment eligibility advice or legal counsel of any kind. We complete Section 2 accurately based on the documents presented. For questions about an employee’s work authorization status, I-9 audit response or immigration compliance strategy, consult a qualified immigration or employment law attorney.
Even when we complete Section 2, the employer faces any civil or criminal penalties for I-9 violations. We exercise accuracy and care on every form. We are not responsible for errors in Section 1 completed by the employee, for the employee’s underlying work authorization status, or for the employer’s retention or audit compliance obligations.