E-Verify v32 Checklist: Vendor, Sites, Remote Review

Put March 31, 2027 on the calendar. Software vendors must complete E-Verify v32 acceptance testing and migrate by then, after which the v31 connection is retired. The v32 case format changes what an E-Verify record must show. Treat the vendor, site list, and remote-review answers as compliance evidence, not IT settings.

The deadline is the vendor's, but the record is yours

U.S. Citizenship and Immigration Services (USCIS) made E-Verify interface control agreement (ICA) version 32 available on September 22, 2026. The cutover is a vendor obligation, but your file still needs proof that the exact connection your company uses will be tested and migrated. Ask the vendor to identify the connection, the test environment, the migration date, and the person responsible for the result. Keep that answer in the same file as the MOU and the site list.

The Enrollment API lets a vendor submit company details, hiring sites, and contacts to E-Verify in a single request. That convenience makes the site list a data decision, not a formality. If a site is wrong at enrollment, the case record can inherit the error. Keep the approved site list with the version date, the approver, and the vendor confirmation.

The employer's memorandum of understanding (MOU) signatory must personally sign within a 24-hour window. The window is short enough that a vacation can become a filing delay. Name a backup signatory if your process allows one, and remind the primary signatory of the 24-hour window.

The case data is the audit trail

A v32 case must identify the employee's hiring site, indicate whether Section 2 documents were reviewed remotely, capture the extension basis for an expired-looking EAD (employment authorization document) or green card, and identify the sending software. Those fields are the difference between a case and a defensible file: if a field is blank, the file will not explain why.

Remote document review is a method, and the case should say so. The I-9 file should show the documents you accepted and the way you verified them. If your process changes after the fact, the file needs a dated note explaining the change.

The E-Verify audit record should be reconstructable without asking the vendor to remember. A remote-review record should be specific enough that another person can follow it without calling the original reviewer: the date, the method, the document type, and the verification step should all be visible.

For an expired-looking EAD or green card, the extension basis is what tells the reader why the date looks old. Record the basis before the case is submitted, because a later note is weaker than a contemporaneous one.

The pilot track is a separate file

If your team is also tracking the E-Verify+ pilot, keep that track separate from the standard cutover. USCIS selected fewer than 10 employers as E-Verify+ pilot participants on May 29, 2024. Keep your ordinary E-Verify file independent of pilot assumptions. Use one folder for the standard program and another for any pilot work, with the same evidence discipline in both.

The checklist turns the cutover into records

Each checklist item should be answerable with a document rather than a status.

• Confirm the actual case submitter for a Workday, ADP, or UKG integration, whether the human capital management system or a partner behind it, because that submitter must pass v32 testing.
• Put the vendor's acceptance-testing evidence for the v32 connection in the file.
• Sync the enrolled hiring sites with the locations where employees actually start work.
• Capture whether Section 2 documents were reviewed remotely, and keep the matching I-9 record.
• Record the extension basis for an expired-looking EAD or green card at case creation.
• Verify the MOU signatory can sign personally within the 24-hour window.
• Check that the sending software appears in the case record.

If an item cannot be answered with a document, leave it open. Keep the documentation with the compliance file.