Hiring teams deal with plenty of onboarding steps, but the I-9 always sits in its own category. It feels simple on the surface—collect documents, verify identity and authorization, move on—but the rules underneath the form can make a normal process feel a little awkward. Especially when you start looking at what documents are allowed and how much an employer can question. The short answer: not much. And that surprise hits a lot of managers the first time they walk through the online process.
What the Employee Can Present
The I-9 uses three buckets of documents—List A, List B, and List C. Most people know that part. What gets confusing is how those lists play out in practice. List A documents prove both identity and authorization, so items like a U.S. passport or a Permanent Resident Card fall into that bucket. If an employee brings one of those, you’re done. The form doesn’t require anything else.
If they don’t bring a List A document, then you look at List B (identity) and List C (work authorization). A driver’s license paired with a Social Security card is probably the combination you see most. And for remote hires, the online verification process follows the same structure—just with an authorized representative acting in your place.
None of this feels complicated until you’re actually reviewing the documents and something looks slightly “off.” Not fraudulent—just unfamiliar. That’s where employers start to hesitate, but hesitation has limits here.
Why Employers Can’t Question Authenticity Too Much
Here’s the part no one loves. Employers aren’t allowed to dig into the legitimacy of a document beyond what the I-9 rules describe as a “reasonable” review. That’s vague on purpose. You look at the document, you make sure it appears genuine on its face, and you confirm that it relates to the person standing in front of you. That’s it. Anything more starts to drift into discrimination territory.
And this is where managers sometimes get stuck. If a document looks different from what they’re used to—an unfamiliar state ID format, an older version of a Permanent Resident Card—they want to double-check. The guidance doesn’t give them room to do much of that. The government expects employers to take documents at face value unless something is clearly wrong. Not mildly odd. Not unusual. Clearly wrong.
This feels counterintuitive because the responsibility for proper completion sits with the employer, yet the authority to question documents is extremely limited. That tension never really goes away.
What Helps the Process Run Smoother
Most companies end up developing informal habits that make the whole experience easier. A quick internal guide with examples of common documents helps. Training supervisors to avoid “helpful” suggestions about which documents an employee should bring also helps, since that crosses the line into document abuse. Keeping the focus on the form—not the person—keeps the process steady.
There’s also the practical reality that online form I-9s add another layer. Your authorized representative becomes your eyes, and their comfort level matters. They don’t have to be experts; they just need enough guidance to understand what “reasonably appears genuine” means.
The I-9 process isn’t complicated, but it lives in a narrow lane. Take the documents the employee chooses. Review them without overthinking. Complete the form. And keep your onboarding moving without turning the document check into a federal investigation.