Form I-9 and E-Verify for Veterinary Practices

USCIS requires all U.S. employers to complete Form I-9 for every individual they hire for employment in the United States, citizens and noncitizens alike.

For a veterinary practice that means every associate DVM, technician, assistant, client-service coordinator and kennel attendant on payroll — there is no small-practice carve-out in the rule.

One carve-out does exist: genuine independent contractors.

Under 8 CFR 274a.1(f), the rule's definition of "employee" excludes independent contractors, so a genuine contractor does not complete an I-9 with you.

The label alone doesn't settle it.

Whether someone counts as an independent contractor for I-9 purposes is decided case by case, regardless of what the person calls themselves — which is exactly the question a relief veterinarian who invoices your practice raises.

If the arrangement walks and talks like employment, assume the I-9 is owed, and work through the full test in our guide to classifying relief staff.

A veterinarian on a work visa completes the same form on the same clock as anyone else, because noncitizens are covered exactly like citizens.

What may differ for a foreign-trained DVM is which documents they present from the Lists — the document rules below cover that.

Two clocks run at every hire.

The employee completes Section 1 — Employee Information and Verification — at the time of hire, under 8 CFR 274a.2.

Your half is Section 2: the employer must complete and sign it within 3 business days of the hire date, and the hire date means the first day of work for pay.

USCIS's own example: a Monday start means Section 2 is finished by Thursday.

Short engagements collapse the window.

If the job lasts less than 3 days, Section 2 must be completed no later than the first day of work for pay — hire someone for a two-day weekend cover and the form is done on day one, not after.

Practically, that argues for building the form into the hire itself: Section 1 finished as part of the signing paperwork, Section 2 blocked into the first-day schedule so the three-day window never gets tight.

The employee chooses what to show: one List A document, which covers both identity and work authorization, or one List B document plus one List C document.

You may not require a specific combination beyond that — and if an employee presents acceptable List A documentation, do not ask for List B or List C on top of it.

One addition if your practice participates in E-Verify: when an employee uses the List B plus List C combination, the List B identity document must contain a photograph.

Then check the edition of the form itself, because USCIS updates it.

As of October 7, 2026, the current Form I-9 edition date is 01/20/25; USCIS also accepts the 08/01/23 edition that carries the 05/31/2027 expiration date.

If you complete the form in software rather than on paper, note that employers using an electronic version had to update their systems to the version expiring 05/31/2027 by 07/31/2026 — so confirm which edition your HR or practice-management system produces before the next hire signs.

The default is physical examination: the employee hands you their documents and you examine them in person.

DHS allows an alternative procedure for examining documents remotely — and only employers participating in E-Verify in good standing qualify to use it.

Everyone else must examine the documents physically.

The alternative procedure has moving parts, and all of them matter: examine copies of the documents, then hold a live video interaction where the employee presents the same documents so they reasonably appear genuine and relate to the individual, and keep clear copies of what was reviewed.

Consistency is the other condition.

If you offer the alternative procedure to new employees at an E-Verify hiring site, you must offer it consistently for all employees at that site; you may instead limit it to remote hires only, provided the practice is not discriminatory.

For a veterinary practice, this matters most when the new hire isn't local yet — an associate finishing a commitment in another state, or a veterinarian arriving from abroad just before the start date.

Decide your site's policy before the hire exists, not the day before they start.

Form I-9 is the universal step.

E-Verify is a separate program — outside state mandates and certain federal contract requirements, USCIS frames it as a program employers participate in rather than a form every practice files.

States add mandates of their own, and their coverage differs: some apply to every employer, others only above an employee threshold.

The table below covers the five state E-Verify mandates for private employers that we verified against the state statutes themselves.

Treat the table as a verified starting point, not a compliance determination for your practice: thresholds and effective dates can change, and the record-keeping side differs state by state.

Before you assume an exemption applies, confirm your state's current requirement with your employment counsel or your state labor department.

Keep each Form I-9 for three years after the date of hire or one year after the date employment ends, whichever is later (8 CFR 274a.2).

A technician hired in June 2025 who resigns in August 2026 is at June 2028 on the three-year clock versus August 2027 on the one-year clock — the June 2028 date wins, so the file stays until then.

Do not file the form with USCIS or ICE.

You keep it, and you make it available for inspection by DHS, Department of Labor or Department of Justice officials — which is the argument for storing completed I-9s somewhere you can produce them quickly, whatever system you use.

The exposure is charged per person.

For paperwork violations, the civil penalty is $288 to $2,861 per relevant individual for penalties assessed after July 3, 2025 (28 CFR 85.5).

Knowingly employing an unauthorized worker is a different order of exposure: a first-order civil penalty of $716 to $5,724 per unauthorized worker on the same assessment schedule.

Confirm the current amounts against the eCFR schedule before relying on them, and treat the three-day completion windows above as cheap insurance.

The I-9 is a small form with hard dates.

Fold it into the same repeatable sequence as everything else in the veterinary hiring hub — offer, verification, paperwork, day one — and the deadlines stop depending on anyone's memory.