I-9 Alternative Procedure (Remote Examination)

Modified on Mon, 14 Sep at 1:59 PM

Purpose

The DHS alternative procedure lets authorized employers examine an employee's Form I-9 supporting documents remotely, over a live video call, instead of reviewing physical documents in person. UZIO records that you used it through the Alternative Procedure checkbox in Section 2. This article explains who may use the procedure, how to document it, and the compliance rules.

Who can do this: An employer user completing Section 2. Federal rules limit the alternative procedure to employers enrolled in E-Verify and in good standing. In UZIO, the checkbox is offered to organizations enrolled in E-Verify through UZIO.

What the alternative procedure is

Under the standard I-9 process, employers must physically examine original documents within three business days of the employee's first day of work. The alternative procedure gives remote and hybrid employers flexibility: document review happens over a live, synchronous video interaction.

Warning: Remote examination is not the same as accepting photos or scanned copies sent by email. You must conduct a live, real-time video review with the employee present on screen.

The DHS-authorized examination has three parts, in this order:

  1. The employee transmits copies of their document(s) to you, front and back if the document is two-sided, before the video call.
  2. You examine those copies to satisfy yourself that the documentation reasonably appears to be genuine and to relate to the employee.
  3. You conduct a live video interaction in which the employee presents the same documents on camera, so you can confirm they reasonably appear genuine and relate to the person in front of you.

Obtain the copies before the live session, never afterwards, and keep them with the Form I-9. Retaining clear, legible copies is a condition of using the procedure, not merely good practice.

Who can use it

The alternative procedure is available only to employers enrolled in E-Verify through UZIO. Employers not enrolled in E-Verify must examine documents physically and cannot use this procedure.

Additional requirements:

  • You must be an active E-Verify participant at the time of examination.
  • The examination must be a live video interaction — not a recorded video or a photo submission.
  • You must retain copies of all documents examined remotely.

How to document it in UZIO

Record the alternative procedure in Section 2 of the I-9:

  1. Open the employee's I-9 form and go to Section 2.
  2. Complete all standard Section 2 fields (document selection and details) as described in Reviewing and Verifying Form I-9 (Section 2).
  3. Check the Alternative Procedure checkbox to confirm the documents were examined via the DHS-authorized remote procedure.
  4. Sign and submit Section 2 as normal.

If you examined the documents in person, leave the Alternative Procedure checkbox unchecked.

Note: UZIO stores your selection on the employee's I-9 record and keeps it in the audit history. It is not sent to E-Verify, because E-Verify has no field for it. The practical consequence: E-Verify will never tell you the box is missing. A case can be created, submitted, and come back Employment Authorized with the checkbox left unchecked on an I-9 where you did examine remotely. Nothing in the E-Verify workflow catches it. The only place it surfaces is an ICE audit of your I-9s. That is why it has to be right at the moment you sign.

Additional Information field

Section 2 includes an Additional Information free-text field for supplementary notes. Use it to record:

  • The date and method of the remote examination (for example, Documents examined via live video call on [date]).
  • Document update details or corrections.
  • Any other relevant information that does not fit elsewhere on the form.

This field is optional but recommended when using the alternative procedure. Like the checkbox, it is stored on the I-9 record and is not sent to E-Verify.

Compliance requirements

Warning: Effective March 16, 2026, ICE reclassified failing to check the Alternative Procedure checkbox when remote examination was actually used from a technical violation to a substantive violation. Substantive violations carry fines of $288 to $2,861 per form, with no cure period.

SituationRequired action
Documents examined in personLeave the checkbox unchecked
Documents examined via live video (alternative procedure)Check the Alternative Procedure checkbox
Employer is not enrolled in E-VerifyCannot use the alternative procedure — physical examination required

Note: For remote examination, you must retain clear copies of all documents the employee presents, obtained before the live video session. (For in-person examination, retaining copies is optional under federal rules unless you are an E-Verify participant examining a List A document that requires photo matching. Follow your organization's retention policy consistently.)

Common problems

Can I use the alternative procedure for some employees and not others?

Only within the federal consistency rules. This is not a free choice per employee.

  • If you offer the alternative procedure to new employees at an E-Verify hiring site, you must offer it consistently to all employees at that site.
  • You may choose to offer it to remote hires only and keep physical examination for onsite and hybrid staff, provided you do not adopt that practice for a discriminatory purpose.
  • You must never decide who is examined remotely and who is examined in person on the basis of citizenship, immigration status, or national origin.

Source: USCIS — Remote Examination of Documents.

What counts as a live video interaction?

Any synchronous video call where you can see the employee and their documents in real time (Zoom, Microsoft Teams, Google Meet, and so on). Pre-recorded videos or emailed photos do not qualify.

Do I need to notify the employee first?

USCIS does not require advance notice, but it is good practice to tell employees during onboarding that document review will occur by video.

The checkbox is greyed out or I can't find it

The alternative procedure is available only to organizations enrolled in E-Verify through UZIO, and only in Section 2, which is completed on the web portal. If your organization is not enrolled, the procedure is not available to you at all. You must examine documents in person. If you believe you are enrolled and still cannot use the checkbox, that is worth reporting; see Still stuck? below.

I completed Section 2 without checking the box, but I did use remote examination

A signed Section 2 cannot be edited, not by you and not by unchecking and re-signing. Do not attempt to correct it by reassigning a new I-9 as though the original were defective. Talk to your legal team first: since March 16, 2026 this is a substantive violation with no cure period, and how you remediate it matters. See Still stuck? below.

Is the checkbox available on the UZIO Mobile App?

No. The Alternative Procedure checkbox is part of Section 2, which employers complete on the web portal.

Still stuck?

If you used remote examination but the Alternative Procedure box wasn't checked before signing, or you're enrolled in E-Verify and the checkbox still isn't available, contact UZIO Support. Please reach out to us at support@uzio.com or call +1-571-601-1752. Send the employee's name and employee ID, the Section 2 signed date, and the date and platform of the video examination. Talk to your legal team in parallel: since March 16, 2026 a missing checkbox on a remotely-examined I-9 is a substantive violation with no cure period, so the compliance question is not one UZIO Support can answer for you.

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