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.

No, E-Verify does not replace Form I-9—all employers must complete I-9 for every employee regardless of E-Verify participation. E-Verify is a supplemental electronic system operated by the Department of Homeland Security and Social Security Administration that allows employers to verify employee work authorization by comparing I-9 information against federal databases, but it functions as an additional compliance step after I-9 completion, not a substitute for the form itself. E-Verify is mandatory for federal contractors, subcontractors, and employers in states with mandatory E-Verify laws (Arizona, Alabama, Florida, Georgia, Mississippi, North Carolina, South Carolina, Tennessee, and Utah as of 2025), while remaining voluntary for other private employers. Nevada does not mandate E-Verify, making it optional for most Las Vegas and Henderson businesses unless they hold federal contracts.

The E-Verify process requires employers to first complete Section 2 of the I-9 form by examining employee identity and work authorization documents, then enter the I-9 data into the E-Verify system within 3 business days of the employee's hire date. E-Verify returns either an "Employment Authorized" result confirming the employee is authorized to work, or a "Tentative Nonconfirmation" (TNC) requiring the employee to resolve discrepancies with SSA or DHS within 8 federal working days. Employers cannot take adverse action against employees based on TNC results alone—the employee must be given the opportunity to contest the finding. E-Verify participation creates additional documentation requirements including retention of case results, employee rights notifications, and anti-discrimination compliance, as improper use of E-Verify (such as pre-employment screening or selective verification based on national origin) violates federal law and triggers separate penalties.

Lake Mead Mobile Notary provides I-9 verification services that create the foundation for E-Verify compliance by ensuring Section 2 is completed accurately before data entry into the E-Verify system. Our mobile notaries serve businesses throughout Henderson, Las Vegas, and Clark County, examining employee documents in person and completing I-9 forms with the precision E-Verify requires—correct spelling of names, accurate document numbers, proper date formatting, and compliant attestations. For employers enrolled in E-Verify, this professional verification service reduces TNC rates caused by data entry errors, ensures I-9 and E-Verify records match during audits, and demonstrates the good-faith compliance effort federal regulators expect when reviewing both I-9 forms and E-Verify case files.

When an employee's work authorization expires, employers must complete Section 3 reverification before the expiration date using either the current I-9 form version or a standalone Section 3 supplement. The employee must present new documentation from either List A (showing both identity and work authorization) or List C (showing work authorization only)—employers cannot require specific documents and must accept any valid documentation the employee chooses to present from the acceptable list. Common scenarios requiring reverification include Employment Authorization Documents (EAD cards) expiring after initial hire, temporary work visas reaching their end date, Temporary Protected Status (TPS) renewals, DACA work permits requiring renewal, and conditional permanent resident cards (2-year green cards) needing replacement with 10-year permanent resident cards.

Missing reverification deadlines is the #1 I-9 audit violation, appearing in 67% of ICE enforcement cases with penalties of $288 to $2,861 per unreverified employee. Employers must track work authorization expiration dates proactively—ideally 90 days before expiration—and cannot continue employing workers whose authorization has lapsed, even by a single day, without completed reverification. The reverification process requires the employee to present unexpired documents, the employer or authorized representative to physically examine them (unless using approved remote verification through December 2025), and proper completion of Section 3 fields including document title, number, and expiration date. Employers should maintain tickler systems, automated HR reminders, or calendar alerts for every employee with temporary work authorization to ensure timely reverification and avoid the severe consequences of employing unauthorized workers after status expiration.

Lake Mead Mobile Notary provides I-9 reverification services throughout Las Vegas, Henderson, and Clark County, helping employers maintain compliance when employee work authorization expires. Our mobile notaries travel to employee locations to examine updated documentation, complete Section 3 accurately, and provide employers with properly reverified I-9 forms that meet federal standards. This service is especially valuable for businesses with distributed workforces, remote employees, or limited HR capacity who need professional assistance tracking and completing reverifications before deadlines. We also offer reverification tracking consultations that help employers identify upcoming expiration dates and implement proactive compliance systems.