From the Hotline: Digital Forms I-9

Question:  Can Forms I-9 be kept digital, or must there be physical copies as well?

Answer: According to the USCIS, it is now possible to store these forms online as well as using a paper system, an electronic system or a combination of paper and electronic systems to store Forms I-9.

“An electronic storage system must:

  • Include controls to ensure the integrity, accuracy and reliability of the electronic storage system.
  • Include controls to detect and prevent the unauthorized or accidental creation of, addition to, alteration of, deletion of or deterioration of an electronically stored Form I-9, including the electronic signature, if used.
  • Include controls to ensure an audit trail so that any alteration or change to the form since its creation is electronically stored and can be accessed by an appropriate government agency inspecting the forms.
  • Include an inspection and quality assurance program that regularly evaluates the electronic generation or storage system, and includes periodic checks of electronically stored Forms I-9, including the electronic signature, if used.
  • Include a detailed index of all data so that any particular record can be accessed immediately.
  • Produce a high degree of legibility and readability when displayed on a video display terminal or reproduced on paper.”

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