I-9 Employment Eligibility Verification: What Ministries Need to Know

At Church HR Network, we recognize the sensitive nature of immigration issues and the important role many churches play in supporting immigrant communities. We are closely monitoring this situation and remain uncertain about how it will unfold. 

Supporting Immigrant Communities in Ministry

Ministries may choose to support immigrant communities by offering resources such as legal referrals, sponsorship opportunities, or other forms of aid. We encourage you to consult your legal counsel for guidance on how best to proceed. If you do not currently have legal counsel and would like a referral, contact us directly.

Why I-9 Compliance Is More Important Than Ever

I-9 compliance has become more critical than ever due to increased enforcement by U.S. Immigration and Customs Enforcement (ICE) and evolving federal regulations. With increasing penalties for noncompliance, even minor errors on I-9 forms can result in significant fines. Additionally, the recent updates to Form I-9 and changes to remote verification procedures post-pandemic have created new layers of complexity. Employers should conduct a thorough audit to ensure proper documentation. Consider using our Audit Services for Ministries to identify and resolve compliance gaps.

Form I-9 Requirements and Employee Rights

According to the Department of Homeland Security, employers must allow all employees to choose which documents to present from the I-9’s List of Acceptable Documents. It is illegal to request specific documents or to base hiring decisions on a person’s citizenship, immigration status, or national origin. Employers may not reject documents simply because they have future expiration dates. 

Key Dates: The New Form I-9

A new version of Form I-9 was released in January 2025, with minor updates related to legal changes and privacy standards. Employers must transition to this version by July 31, 2026, when the current edition expires. The new form, with an expiration date of May 31, 2027, is available now for download. 

Step-by-Step: How to Complete Form I-9

Completion of the I-9 should follow this sequence.  

1. Employee accepts offer for employment.  
2. Employee completes Section 1 of the form no later than their first day of paid work.  
3. Employee provides original documents and form to employer.  
4. Employer completes Section 2 of the form no later than the third business day after the employee begins work.  
5. If the employee’s work authorization expires, complete Supplement B.  

Understanding the Three I-9 Document Categories

I-9 documents fall into three categories: 

• List A: Establish both identity and work authorization (e.g., U.S. Passport).  
• List B: Establish identity only (e.g., driver’s license). 
• List C: Establish work authorization only (e.g., Social Security card).

Fixing Errors on Existing I-9s

If you identify a missing or incorrect I-9 form:

• Correct the original form and include a note explaining the correction, or
• Complete a new form with a written explanation

Never conceal past mistakes—transparency and documentation are essential.

Stay Compliant with Confidence: Tools, Guidance, and Expert Support for Ministries

I-9 compliance can be complex—but your ministry doesn’t have to navigate it alone. With evolving regulations, increased enforcement, and updated verification procedures, having the right tools and guidance is essential to protect your organization and honor your mission.

To help you take the next steps:

• Visit our Document Library for ready-to-use compliance tools and templates.
• Refer to the official Handbook for Employers (M-274) for comprehensive federal guidance from USCIS.
• Review our Employee Handbook Services to ensure your internal policies align with current I-9 requirements.

Church HR Network is here to support your ministry every step of the way. Whether you need help conducting an audit, updating your onboarding process, or training your team, we offer ministry-focused solutions to keep you compliant and confident. Explore our HR Project Services or contact us to get started.