Remote verification of I-9 documents is allowed through December 31, 2025, under DHS's flexible verification policy, but physical document inspection remains required within 3 business days of the employee's start date or when normal in-person operations resume. This temporary accommodation applies only to employers operating entirely remotely or whose employees work at locations where no authorized representative can physically meet them during the verification window. Multi-state remote workers create additional complexity when state employment laws, tax requirements, and federal I-9 obligations intersect—for example, a Nevada employer hiring a remote worker in California must comply with both federal I-9 rules and California labor law notice requirements, while ensuring the authorized representative examining documents follows proper verification procedures regardless of the employee's physical location.

Best practices for remote worker I-9 compliance include: using authorized representatives located near remote employees for in-person document examination, conducting video conference verification only when truly no in-person alternative exists and documenting why physical inspection was impossible, retaining detailed records of remote verification sessions including screenshots of documents examined and explanation of circumstances requiring remote verification, scheduling physical document inspection as soon as the remote employee visits a company location or travels to an area with authorized representative coverage, and implementing clear written policies explaining when remote verification is permitted versus when in-person verification is required. Many employers incorrectly assume remote verification is a permanent option or automatically available for any remote worker, but DHS guidance emphasizes that physical document examination remains the standard and remote alternatives must be justified by genuine operational constraints.

Lake Mead Mobile Notary eliminates remote verification compliance risks by providing in-person I-9 verification for remote workers throughout Nevada and neighboring states. Our mobile notaries travel to remote employee home offices in Henderson, Las Vegas, Boulder City, and throughout Clark County, completing Section 2 with proper physical document examination that satisfies all federal requirements without relying on temporary remote accommodations. For employers with remote workers outside our service area, we coordinate with trusted notary networks nationwide to arrange compliant in-person verification, ensuring every I-9 meets audit standards regardless of where your employees work. This approach creates audit-ready I-9 forms from day one and avoids the documentation burden of justifying why remote verification was necessary.

Both staffing agencies and client companies share I-9 responsibility, but the initial completion obligation typically falls on the staffing agency as the legal employer of record. When a staffing agency places a temporary or contract worker at a client company, the agency must complete the employee's I-9 form (Sections 1 and 2) within the standard 3-business-day timeframe from the employee's first day of work at the client site. However, client companies can be held jointly liable for I-9 violations if they exercise sufficient control over the worker's employment terms, work conditions, or termination decisions—a determination ICE makes based on factors like who sets schedules, who supervises daily work, who provides equipment, and who determines compensation rates. This joint liability means both parties face penalties if the I-9 is incomplete, incorrect, or fraudulent, potentially doubling the financial exposure for a single violation.

To manage this shared risk, many staffing arrangements include contractual clauses specifying which party assumes primary I-9 responsibility and how compliance verification will be documented. Best practices include: staffing agencies completing initial I-9 verification before sending workers to client sites, client companies conducting secondary identity verification upon worker arrival (though not completing a duplicate I-9), both parties maintaining records demonstrating due diligence in employment eligibility verification, and clear communication protocols when reverification becomes necessary due to work authorization expiration. Client companies in high-risk industries—hospitality, healthcare, construction, manufacturing—often require staffing agencies to provide certified copies of completed I-9 forms and proof that authorized representatives properly examined identity documents, creating an audit trail that demonstrates both parties fulfilled their obligations.

Lake Mead Mobile Notary serves as an authorized representative for I-9 verification for both staffing agencies and client companies throughout Las Vegas, Henderson, and Clark County. For staffing agencies, our mobile notaries travel to new employee locations—homes, co-working spaces, or client sites—to complete Section 2 verification before the worker's first shift, ensuring compliant I-9s before placement. For client companies receiving temporary workers, we provide verification services that document proper identity checks without creating duplicate I-9 forms that violate federal rules. This dual-service approach helps both parties maintain Summerlin South area compliance, reduce joint liability exposure, and demonstrate the due diligence ICE expects during audits of staffing arrangements.