To: T&L Clients & HR Compliance Teams
Subject: E-Verify Update
The U.S. Department of Homeland Security (DHS) and U.S. Citizenship and Immigration Services (USCIS) have introduced a new compliance requirement for employers enrolled in E-Verify: regular generation and review of the “Status Change Report” to identify noncitizen employees whose work authorization may have been revoked due to changes in immigration status. Effective June 20, 2025, E-Verify will no longer issue automatic Case Alerts when an employee’s EAD is revoked due to the termination of Temporary Protected Status (TPS), humanitarian parole, or similar programs. Instead, employers are now required to regularly generate and review the new “Status Change Report” within the E-Verify system. See New “Status Change Report” for E-Verify Users. Note, qualifying Agencies may access the same report through their SAVE Account.
What Employers Need to Know
- Status Change Report: Accessed through your E-Verify portal, this new report identifies employees whose EADs have been revoked, even if the document appears valid and unexpired on its face. See: Status Change Report Updated to include Document Number.
- Frequency: Employers should generate the report regularly (i.e., bi-weekly, monthly, etc.) to ensure timely identification of affected employees. The report will contain the document revocation date, case number, and A-number for each affected case. See EAD Revocation Guidance For E-Verify Employers. Employers must decide how regularly they want to review the report, our office suggest no longer than every 60 days.
- Reverification Requirement: If an employee appears on the report, employers must “immediately begin reverifying each current employee whose EAD the Status Change Report indicated was revoked, and complete all reverifications within a reasonable amount of time” using Form I-9, Supplement B: Form I-9, Supplement B. Employers must decide how much time they want to provide the employee to complete re-verification, our office suggest no longer than 90 days.
- Do not create a new E-Verify case as reverification is handled through Form I-9 only.
- Employee Notification: Employees may still be authorized to work under a different lawful status and can present alternate documentation.
- Compliance Risk: Failure to act promptly may result in unauthorized employment and potential Civil Penalties.
- Avoid Discriminatory Practices: Ensure compliance with anti-discrimination laws when requesting updated documents.
- Due to the constantly changing policies/regulations affecting EAD terminations, revocations, AND court-ordered reinstatement of work authorization, we strongly recommend visiting I-9 Central website for latest “NEWS” regarding the specific work authorization in question prior to reverification. See https://www.uscis.gov/i-9-central/form-i-9-related-news
Recommended Action Steps
- Update Internal Protocols: Incorporate routine generation of the Status Change Report into your HR compliance calendar.
- Train HR Personnel: Ensure staff are familiar with Form I-9, Supplement B procedures and reverification timelines.
- Secure Data Handling: Treat the report as sensitive personal data and ensure secure transmission and storage.
- Consult Legal Counsel: Contact our team for specific training above, assistance with policy updates, internal audits, and case-specific guidance.
This change reflects a broader shift in responsibility from government alerts to employer-initiated compliance. We strongly advise all E-Verify participants to act swiftly to align with the new requirements. For questions or support, please reach out to your designated T&L attorney.