Form I-9 Employment Eligibility Process

Every paid employee of the University must complete the Form I-9. This includes:

• Newly hired faculty, staff, and student employees as well as casual and temporary workers who are paid by voucher or on a flat-rate basis.
• Anyone listed above who is rehired (who had a one-day or longer break in service) must complete a new I-9 Form. Completing supplement B for rehires will no longer be an acceptable process when using Equifax.
• Anyone in a 0% assignment before some form of payment (one-time payment, award, stipend, etc.) through UT Payroll is administered. If there is no record of I-9, payment will be held until compliance is met. 

• Section I of the Form I-9 employment verification process can be completed after the hire is accepted and must be completed by the employee no later than the end of their first day of employment. In order to complete Section I of the Form I-9, employees will be required to provide certain biographical information to an Equifax Representative or by the hiring department’s I-9 Partner.
• Section II of the Form I-9 employment verification process can be completed after the employee completes section I and must be completed within three business days of the first day of employment (if the employee starts on Monday, the I-9 Form must be completed no later than Thursday). Employees must show original, un-expired, valid government-issued documentation establishing their identity and eligibility to work in the United States in order to complete Section II of the I-9 Process.  A List of Acceptable Documents for the I-9 Process can be found here. 

EXCEPTION: If an employee’s U.S. Citizenship status is denoted as “noncitizen authorized to work” and waiting on their social security number from the Social Security Administration, Form I-9 Section 2 will be completed upon receipt of the employee’s social security number which will exceed the normal Form I-9 submission timeframe. Please note that the employee must apply for their social security number prior to submitting Section 1.

I-9 forms may be completed up to six months before an employee’s start date if the employee has successfully completed a background check and accepted a job offer.

Hiring departments will have three location-specific Equifax Quick Start links. During Onboarding, I-9 Partners can either have Workday send the Virtual Equifax I-9 Anywhere Quick Start Link to employees or choose to send an Equifax Quick Start link themselves via email outside of Workday.

Location Quick Start links appear on the Additional Data Tab for I-9 Partners in the Dean/VP PM Supervisory Organization or by running the Equifax Locations, Emails, Users - RPT1197 in Workday. The table below lists three link types used to manage the Form I-9 Process.

* Supplement B will only be used for Noncitizens Authorized to Work who have expiring documents.

** All documents uploaded to UT devices should not be retained and must be immediately deleted after uploading them to Equifax. 

Equifax I-9 Anywhere dedicated call center for section two completion:

Virtual Completer Hours (English):

• Monday - Friday: 7 a.m. - 7 p.m. CT
• Saturday: 8:30 a.m. - 5 p.m. CT

Spanish Language Hours:

• Monday - Friday: 7 a.m. - 6 p.m. CT

• I-9 Partners must be assigned to the CSU Dean/VP Supervisory Organization to access Equifax I-9 Management. Equifax Login. For further details, please contact your HR Executive.
• I-9 Partners are responsible for ensuring employees receive the link to Equifax to begin their I-9 process, monitoring employee I-9 status in Equifax, and taking necessary actions such as reverifications, addressing pending SSNs, and photo-matching. Employees who do not follow the outlined I-9 regulations will be subject to termination.
• Notifications from Equifax will be directed to the CSU Location Email address. To view the CSU location information, I-9 Partners can run “Equifax Locations, Emails, Users – RPT1197". 

• Issue Reporting: I-9 Partners submit tickets on behalf of themselves and employees to Equifax Workforce Solutions Service team. 
  o    Email: workforcesolutionssupport@equifax.com 
  o    Phone: 877-664-8778
  o    Hours: Monday-Friday 7 a.m. to 7 p.m. Central Time
  o    Saturday: 8:30 a.m. to 5 p.m. Central Time 

The United States Citizenship and Immigration Services (USCIS) agency enforces that employers have certain responsibilities under immigration law during the hiring process. Employers who violate the law may be subject to penalties and fines as explained on the (USCIS) website. In addition, non-compliance can result in the loss of federal contracts.

We all have a responsibility to assist the University in complying with our obligations under federal immigration and employment law. Any employee who fails to complete the I-9 verification process within the prescribed time limits must be terminated according to federal law.

• Send one of the UT quick links for your location to the employee explaining the need to initiate a new I-9 in Equifax.
• Upon completion of section 2, add this comment: “Original I-9 was initiated in Workday; Section 1 was completed within required timeframe. New I-9 launched due to University moving to Equifax I-9 Management System on Oct. 13, 2025.”
• The HR Service Center team will cancel the I-9 Business Process in Workday once the employee has initiated their I-9 in Equifax.

• Work Authorization Expiring Alerts have been disabled, and I-9 information will no longer be updated in Workday.
• Send one of the UT quick links for your location to the employee explaining the need to initiate a new I-9 in Equifax.
• Upon completion of section 2, add this comment: “New I-9 launched due to University moving to Equifax I-9 Management System on Oct. 13, 2025.”
• This will ensure that you receive alerts from Equifax when work authorizations are expiring. 

• Employees must use their legal name as it appears on their identity and work authorization documents when completing Section 1 of Form I-9.

• Choosing the correct citizenship status is critical. Mistakes can trigger E-Verify delays or kickbacks, requiring extra follow-up and risking compliance issues.

• Yes. Since UT is an E-Verify employer, employees must enter their Social Security Number (SSN) in Section 1 of the Form I-9. If an employee does not have an SSN, they should select the 'SSN Applied For' option and attach a receipt. The employee then has 30 days to provide their assigned SSN.

• Click here for information on applying for a Social Security Number.

• Yes. Since UT is an E-Verify employer, the employee is required to provide a list B document that contains a photo if using Lists B & C for verification OR a photo document from list A for verification. Click here to view a list of acceptable documents.

• The employee is responsible for completing Section 1. They may use a translator if they do not understand enough English to complete it. However, the translator must complete the Preparer and/or Translator Certification block. The employee must still sign the certification block in Section 1.

• Beginning October 13, 2025 the Form I-9 Process in Workday will be replaced with a “To Do” task for the I-9 Partner to send the employee their Equifax location link to complete their Form I-9.
• For Hires and Rehires, the I-9 Partner will have the option to send the Virtual Equifax  I-9 Anywhere Quick Start Link via Workday, which automatically populates Section 1, or to send a link via email outside of Workday.   
• The I-9 Partner assigned to the employee’s position supervisory organization will be responsible for completing the “To Do”. 

I-9 Process in Workday with Equifax for CSUs (PDF)

• Employees who are unable to meet federal Form I-9 requirements cannot lawfully be employed. Also see “What are the penalties for non-compliance?” above.

• Termination dates will be populated in Equifax through a centrally managed  integration upload process and will not be the responsibility of I-9 partners.

• E-Verify is a free web-based service that electronically verifies the employment eligibility of newly hired employees and existing employees assigned to work on a qualifying federal contract. E-Verify compares information from an employee’s I-9 to U.S. Department of Homeland Security and Social Security Administration records to confirm employment eligibility.
• As a federal contractor, UT is required to use the E-Verify system to verify employment eligibility of employees working in the United States on assignments paid by a federal contract that includes the Federal Acquisition Regulation (FAR) E-Verify Clause. 

• Texas requires state agencies, public colleges, and their contractors to use E-Verify. E-Verify is used to reduce unauthorized employment and to minimize verification related discrimination.

A Tentative Non-Confirmation (TNC) means the information entered in E-Verify from the Form I-9 doesn’t match records from the Department of Homeland Security (DHS) and/or Social Security Administration (SSA). This does not necessarily mean the employee is not authorized to work in the U.S.
The employee must be notified of the mismatch, which may come from DHS, SSA, or both.

IMPORTANT
Employers may not terminate, suspend, delay training, withhold or lower pay, or take any other adverse action against an employee because of the mismatch, until the mismatch becomes a Final Nonconfirmation.  If the employee chooses not to take action on the mismatch, the employer may terminate employment with no civil or criminal liability as noted in "Responsibilities of the Employer," Article II, Section A paragraph 13 of the MOU.  The case can be treated as a Final Nonconfirmation and the employer should close the case in E-Verify.
 

A Final Non-Confirmation (FNC) occurs when E-Verify cannot confirm an employee’s work eligibility because:

• The employee contacted DHS or SSA, but the issue was not resolved;
• The employee did not contact DHS or SSA within 8 federal working days;
• The employee did not inform the employer of their decision to take action within 10 federal working days.

Employers must close the case after an FNC result and may terminate employment without liability, as outlined in the MOU.

Non-Confirmation Workflow (PDF)