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Fact check: What are the differences between ICE Form I-9 and Form I-551 for citizenship verification?
Executive Summary
Form I-9 is an employer-facing verification process used to confirm an employee’s identity and authorization to work in the United States, while Form I-551 is a government-issued permanent resident card (Green Card) that functions as documentary evidence of lawful permanent residency and work authorization. The two interact because an employer may accept Form I-551 as a List A document on Form I-9, and recent guidance addresses facially expired cards extended by Notices of Action for continued employer acceptance in electronic checks like E-Verify+ [1] [2] [3]. Understanding procedural differences is critical for compliance and for LPRs’ rights during reverification or replacement processes [4].
1. Why Employers Use One Form and Individuals Hold the Other — The Practical Divide
Form I-9 is an administrative work-authorization verification tool that every U.S. employer must complete for new hires to document identity and employment eligibility; it is not a document issued to an individual but a form filled out by employer and employee together, per the provided analyses [5] [6]. Conversely, Form I-551 is a physical government-issued credential—the Green Card—that proves a specific immigration status (lawful permanent resident) and inherently provides the right to work. The distinction matters because compliance obligations rest with employers via Form I-9, while the I-551’s role is evidentiary: it is one acceptable proof an employee can present to satisfy the employer’s I-9 obligations [1] [7].
2. What the Records Show About Document Categories and “List A” Use
On Form I-9, documents fall into Lists A, B, and C; Form I-551 is explicitly a List A document, meaning it alone establishes both identity and work authorization when presented unexpired [3] [5]. The guidance cited in the analyses also explains that if an LPR presented an unexpired I-551 at initial completion, employers generally do not reverify that lawful permanent status later even if the card later expires, reinforcing the I-551’s durable evidentiary weight for the I-9 process [3]. This delineation is essential for employers deciding when reverification steps are required versus when original documentation remains sufficient.
3. How Expired Cards and Notices of Action Complicate the Picture
Analyses note that a facially expired I-551 may still be accepted in certain electronic verification programs like E-Verify+ when accompanied by a Form I-797 or I-797C indicating an extension or receipt of a replacement application, creating a pragmatic bridge for employees awaiting new cards [2]. This nuance means employers and E-Verify users must track not just card expiration dates but also whether the employee holds contemporaneous USCIS notices extending proof of status. The presence of these notices can affect whether a facially expired I-551 functions as acceptable List A evidence in practice, and the cited date for that guidance was December 3, 2025, indicating recent policy application [2].
4. Administrative Consequences: Reverification Rules and Timing
The provided analyses emphasize an important administrative rule: employers are not required to reverify lawful permanent residents who presented an unexpired I-551 at initial Form I-9 completion, even if the card later shows an expiration date [3]. This reduces employer burden but places responsibility on employers to correctly record the initial documentation and not treat later expiration as an automatic trigger for reverification. By contrast, other non-permanent authorization types do require reverification when authorization expires, underscoring the distinct legal treatment of Form I-551 evidence within the I-9 framework [5] [7].
5. Replacement Processes and Interim Evidence for Employees
When a Green Card is lost, stolen, or needs replacement, the analyses indicate that filing Form I-90 is the formal replacement route and that the receipt notice for I-90 can serve as interim evidence of LPR status, which affects what employers can accept for Form I-9 purposes and for programs like E-Verify+ [4] [2]. This procedural detail matters to employees and employers during transitions: employees maintain evidence of status while awaiting the new card, while employers must recognize which interim documents remain acceptable to avoid wrongful termination or unlawful hiring practices [4] [2].
6. Bottom Line: Complementary Roles with Different Legal Functions
In sum, Form I-9 and Form I-551 are complementary but legally distinct: one is a mandatory employer verification process, the other is documentary proof of permanent residency and authorization to work. Employers must apply I-9 rules — including List A acceptance, reverification exceptions for LPRs, and treatment of extension notices or I-90 receipts — to remain compliant, while employees rely on Form I-551 (or acceptable interim documents) to establish their continuing right to work [1] [3] [4]. The supplied analyses show recent clarifications about expired cards and notices that employers should incorporate into their verification practices [2].