Action Required: Form I-9 Expiring July 31, 2026

Beginning August 1, 2026, employers must replace Form I-9 (08/01/23 edition) with an expiration date of 07/31/2026 with either the 01/20/2025 edition or the 08/01/23 edition with an expiration date of 05/31/2027 for new hires.

What You Should Do

• Review your current Form I-9 to verify the expiration date in the upper-right corner.
• Replace any paper forms that expire on 07/31/2026 before August 1.
• Update electronic I-9 systems to ensure they generate the current version of the form.
• Train HR staff and hiring managers on the updated form to prevent the use of an expired version.
• Do not reverify or complete new I-9s for existing employees solely because the form has expired.

A Critical Compliance Reminder

Using an expired Form I-9 for an employee hired on or after August 1, 2026, is not considered a correctable technical error. If an employer completes the wrong version of the form after the expiration date, it may be cited as a substantive violation during a government audit and could result in penalties. Unlike certain technical or procedural errors, using an expired version of the Form I-9 cannot simply be corrected by making a notation on the existing form.

Taking a few minutes now to verify your forms, update your onboarding process, and educate anyone responsible for completing Form I-9s can help your organization avoid unnecessary compliance risks.

If you have further questions or need assistance, contact us for guidance and support. MRA members can reach our 24/7 HR Hotline or by telephone at 866-744-6854.