Complete the I-9 reverification sweep for Somalia TPS EADs before Aug 14, 2026

The deadline is the trigger

The deadline is August 14, 2026. DHS, the Department of Homeland Security, ended Somalia's TPS designation on that date. USCIS confirmed the termination in updated guidance issued the same day. That guidance replaced an earlier agency message dated August 12, 2026.

USCIS cited the June 25, 2026 Supreme Court ruling in Mullin v. Doe as part of the legal context for ending Somalia TPS. The agency also said former DHS Secretary Kristi Noem had earlier concluded that Somalia failed to meet the statutory TPS conditions after a country-conditions review.

The rule is a stop-work decision

A Somalia TPS EAD that is no longer valid after the August 14, 2026 termination is a reverification trigger. USCIS told employers to reverify workers who had used those EADs on Form I-9. It also told employers to stop employing anyone who cannot show current work authorization.

The date is the trigger. Before August 14, 2026, the EAD can be the authorization. After August 14, 2026, it cannot. The I-9 file should show the change in status, not just the old card. A clean file answers three questions: who was affected, what replaced the EAD, and when work stopped if nothing replaced it.

The practical effect is simple. An employee who kept working on a Somalia TPS EAD after the termination date is not holding current authorization. The file needs a new document or a documented stop-work decision. The sweep should be narrow enough to finish in one pass. It should also keep the terminated Somalia group separate from any other TPS designation. That separation prevents a placeholder from becoming a work authorization.

The sweep should not wait for a formal audit. It should run while the file is still open. A short note in the file is better than a long explanation after the fact.

The sweep should start with the EAD

Start with the work-authorization document, not the immigration history. Pull the I-9 file for every employee whose original work-authorization document shows a Somalia TPS EAD. Check the card number, expiration date, and the country code printed on the card. If the card is a Somalia TPS EAD, mark it for reverification. Payroll flags can help, but the I-9 file controls.

The reverification step is where the new authorization goes. A List A document can stand alone, while a List C document must be paired with identity evidence. The employee chooses the document, but the employer records it in Supplement B.

If the employee says a renewal is pending, the file still needs a current document. A pending application is not current authorization. The stop-work decision can be short, dated, and tied to the missing document.

Do not let the sweep become a citizenship audit. The question is narrow: did the employee present a Somalia TPS EAD, and is there current authorization now? If the answer is yes and no, the stop-work decision follows. If the answer is yes and yes, the file closes with the new document.

The file should not rely on memory. It should show the date the old authorization ended, the date the sweep identified the employee, and the date the new document was received or work stopped.

The workaround is a stop-work record

Each item below is a test you can run in a minute. The list is the part of the file you keep.

1. Identify employees who presented Somalia TPS EADs.
2. Complete the I-9 Supplement B reverification with a new List A or List C document before the employee continues working.
3. Stop employment if no valid authorization is produced.
4. Keep any other TPS designation separate from the terminated Somalia TPS group.

The first item narrows the population. The second creates the record. The third protects the company. The fourth keeps the legal status clean.

Keep the stop-work note separate from the I-9 correction. The I-9 shows the document. The note shows the business decision. If the employee later produces a current document, the note can be closed with a date. If the employee does not produce one, the note remains the last entry.