E-Verify Flags a Revoked EAD: I-9 Reverification Workflow

The next E-Verify Status Change Report refresh is the deadline to watch. E-Verify says it will keep updating the report data on a bi-weekly cycle as new information arrives. E-Verify said on August 11 that the Status Change Report now covers a wider set of cases. Treat a flagged EAD as a standing I-9 reverification trigger.

The expanded report makes regular review an I-9 duty

Employers enrolled in E-Verify must review the report on a regular basis and finish any needed Form I-9 reverifications. Put the report in the I-9 compliance file, not in a separate E-Verify inbox. A flagged EAD starts a decision chain: identify the person, check current employment eligibility, decide whether reverification is required, and record the result. The file needs to show why the employer acted, what document supported the action, and what was deliberately left unchanged.

Run the bi-weekly review before the fine math catches up

For 2026, ICE, the federal agency that enforces I-9 rules, may assess a fine of $288 to $2,861 for each Form I-9 with a substantive violation. In 2026, ICE guidance counts missing or incomplete Supplement B, formerly Section 3, Rehire and Reverification, as a substantive I-9 violation. Failing to respond to the expanded report raises the risk that the employer is knowingly employing someone without work authorization.

The fine math is not the only reason to move quickly. A missing reverification can sit in the file while the employee continues working, and the employer's exposure grows with each day the gap remains. The cleanest defense is a contemporaneous record: the report date, the flagged category, the document examined, and the completed form page.

Run the reverification when a flagged EAD appears

• Set the review cadence. Put the E-Verify Status Change Report on a bi-weekly calendar. The finished step looks like a named owner, a saved report date, and a log line for each review.
• Flag the EAD categories. DHS, the federal agency behind E-Verify, says the expanded report is meant to help employers spot E-Verify cases that used A12, C08, C09, C11, or C19 EADs and were later invalidated by DHS. Mark those rows for employment eligibility review. You are done when a short note names the employee, the EAD category, and the date you saw the flag.
• Verify current work authorization. Ask the employee to present a current List A document or a current List C document, and compare it to the I-9 file. Do not treat a clean E-Verify result as proof that no reverification is needed. The record needs to show which document was examined, the expiration date, and whether it matches the flagged EAD.
• Complete Supplement B. If the employee presents acceptable proof, complete Supplement B and attach the new document or note. The form page must be signed, dated, and tied to the flagged report entry.
• Document that List B was not re-verified. Write a short note explaining that the reverification addressed employment eligibility only, and that the original identity document was not re-examined. The file note lets an auditor understand why the I-9 looks partial.

Make the file audit-ready before the next refresh

After the workflow is complete, close the loop with a short decision memo. It should say what the report showed, what the employee presented, what was completed, and what was intentionally not re-verified. If no reverification is needed, the memo should say why, with enough detail that another reviewer can reach the same conclusion.

Keep the memo in the I-9 file, not only in an email thread. A separate email is useful, but it is not a substitute for the form page and the supporting note. A defensible file reads like a sequence: report reviewed, flag identified, document checked, Supplement B completed, and the identity question left alone.