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Most employers know the basics of Form I-9: Section 1 completed by the employee, Section 2 by the employer. But two supplemental components catch many HR teams off guard. Supplement A handles situations where someone helped the employee complete the form. Supplement B manages reverification and rehires. Getting these wrong is a compliance problem whether you encounter them rarely or constantly.
Supplement A: Preparer and/or Translator Certification
Supplement A is required any time a preparer or translator helped an employee complete Section 1 of Form I-9. If the employee completed Section 1 entirely on their own without assistance, Supplement A isn’t needed, and employers aren’t required to print or retain blank supplement pages. But if an HR representative, interpreter, family member, or any third party assisted the employee in completing the form, Supplement A must be completed and signed by both the preparer or translator and the employee.
When Is a Preparer or Translator “Required”?
A preparer is anyone who helps fill out the form, including someone who verbally clarifies questions. A translator is anyone who translates information into the employee’s native language, including over the phone. Simply handing the form to an employee and saying “fill this out” does not require Supplement A, even if the employee struggles. But actively assisting or translating does. When in doubt, complete Supplement A. It’s a simple form that eliminates ambiguity.
Supplement B: Reverification and Rehires
Supplement B covers two situations: reverification, when an employee’s work authorization expires and must be re-verified, and rehire, when an employee is brought back more than three years after the original I-9 was completed. Employers often forget to complete Supplement B on reverifications, or they mistakenly create a new I-9 instead. Using the wrong form is a violation.
Bottom Line
Supplements A and B are straightforward forms. But they’re easy to overlook. Build them into your standard I-9 workflow: always complete Supplement A if any assistance is provided, and always complete Supplement B, not a new I-9, for reverifications or rehires beyond three years from the original.
Frequently Asked Questions
The information provided is for educational purposes only and should not be construed as legal or tax advice. Consult a tax professional or attorney regarding your specific situation.
I-9 Compliance Management
Netchex tracks I-9s, supplements, reverifications, and rehires automatically.
The information provided is for educational purposes only and should not be construed as legal or tax advice. Consult a tax professional or attorney regarding your specific situation.
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