I-9 Section 2 Workflow Setup

Setup and completion options for Section 2 of the I-9 form

June 5, 2025

Section 2 of the I-9 form, which is either filled out by you as the employer or an authorized representative, is the second step in the I-9 workflow.

This step involves reviewing, confirming, and signing off on the information and documents that the employee provided in Section 1.

Important Note:

Section 2 must be completed no later than three days after the employee’s first day of work for pay.

Fountain’s Digital I-9 Approach

Fountain’s I-9 Center offers flexibility in how you and your employees complete Section 2 of the I-9 process.

You will have two main decisions to make when it comes to completing Section 2: who completes the review and how the review is completed. With Fountain, you can choose just one of the methods below for all of your new employees, allow your new employees to select from multiple options, or show different options based on previously created segments.

Who completes Section 2:

Section 2 can be completed by one of two people:

• Employer: requires the employer to examine the presented documentation to verify that it is legitimate.

• Authorized Representative: requires a designated representative to verify the documents on behalf of the employer. The designated representative will be chosen by the employee. However, the designated representative cannot be the employee themselves.

• This option can be beneficial in reducing the I-9 workload on your HR team.

How the review is completed:

1. In-person: requires the employer to physically review the documents in person with the employee. This must be done within 3 days of the employee's first day of work.

2. Remotely: request the employer to review the documents virtually via live video with the employee.

• Review copies of the I-9 form documents or an applicable document receipt to ensure they appear genuine.

• Conduct a live video call with the employee presenting the document(s) to confirm their authenticity and relevance.

• Check the alternative procedure checkbox when completing Section 2.

• Keep a clear and legible copy of the documentation.

• Provide clear copies of the identity and employment authorization documentation during an I-9 form audit or investigation.

Important Note:

If your company utilizes this alternative procedure with E-Verify at any hiring site (a location where employees are hired and complete their I-9 forms), then all new employees for that hiring site must be offered the option to use the alternative procedure.

One exception to this requirement is that if a hiring site hires both in-person and remote employees, then that site has the option to only use this alternative procedure for its remote employees.

Fountain Document Review Options

No matter who you decide to review the document and complete the verification for Section 2, the I-9 Center will support your process.

Employer-based review:

1. Standard I-9: Using our standard scheduler functionality, the employee schedules an on-site document review with you, the employer.

2. Remote I-9: Also utilizing our scheduler functionality, the employee schedules a live video call with you, the employer, to validate their documents over live video call.

Authorized representative review:

1. Smart I-9: The document review is completed in person by an authorized representative of the employee's choosing.

2. I-9 End-to-End: The employee schedules a live video session with a Fountain-trained professional, who will review and validate their documents.

If you are interested in I-9 End-to-End, contact your Fountain Customer Success contact or support@fountain.com for more information.

Fountain Section 2 Verification Options

When setting up an I-9 task within the Fountain platform, you can select one or more methods to offer employees when completing Section 2.

Fountain’s dynamic segment functionality allows even more flexibility by allowing you to set each option by different data points such as the employee’s job, location, or any other employee attribute.

To select your Section 2 verification, follow the steps below:

1. Within Worker Experience, click Onboard in the left side panel.
2. Click +Add Flow in the top right corner.
3. Type a name for the I-9 flow, select the task flow type, and type a description.
4. Click Next.
5. Click +Add a task and select I-9 from the dropdown. If you do not see this as an option, contact your Fountain Customer Success contact.
6. Type a Title for the task which will be seen by your workers. You can also update the estimated task completion time which will default to 10 minutes.
7. Select the verification method by turning on the toggles.

• Some options will require additional setup. More information on these options can be reviewed in the next section of this article.

8. Click Next and finish the Flow creation steps. Learn more about Onboarding Flow creation by reviewing this article.

Tips!

• Click the checkmark icon to recommend one of the options to your workers if you have more than one option for them to choose from.

• You can also reorder the options if you have selected multiple to show in a specific order to your workers.

Verification Method Options

Learn more about the verification method options below:

• Authorized Representative: The employee selects an adult, other than themselves, to review and verify their documents.

• On-Site Verification: The employee sets up a time to have their documents reviewed physically on-site at a work location.

• Live Video Verification: The employee sets up a time to have their documents reviewed over a live video call. Remember, you must meet the requirements outlined earlier in this article to be eligible to use this method.

On-Site and Live Video Additional Steps

The On-Site and Live Video Verification options require an additional setup step which requires connecting your external calendar in order to display available time slots to your new employees to schedule documentation review. Review this article for the calendar setup instructions.

The required fields you must complete are:

• Meeting duration: The amount of time in minutes for each verification meeting.

• Description (optional): A description of the I-9 verification meeting which will be shown in the meeting invite to your employee.

• Calendar Group: Select which of the employer admin calendars will be used to set up documentation review time slots with employees.

• Reminders (optional): Allows you to create an email reminder sent to the meeting host and employee before the documentation review.

Check the "Enable this to enter a custom meeting link URL for meetings" checkbox to add the following additional fields for Live Video meetings:

• Provider Description (optional): The name of the video call provider (ex. Zoom), which will show in the event calendar invitation to the employee.

• Live Video URL (optional): The URL that the employee will click on to join the virtual meeting.

Employee Experience

If multiple Section 2 completion methods are available for a worker to choose from, once they complete Section 1 in their worker portal, they’ll be shown all available options for completing Section 2.

If the worker selects the authorized representative option, they will move into the authorized representative flow. Review these steps in this article.

If the worker selects the On-Site Verification option, they will be presented with a list of available time slots based on previously set up slots in your calendar.

Retaining forms

Once both sections have been verified and completed, the completed I-9, including copies or images of the employee-provided documents, must be kept on file for as long as the employee works for the company, and for a period of time after.

If the U.S. government requests an inspection of your employee’s I-9 documents, you must provide them within three business days.

• If the employee worked for less than two years, you must retain their forms for three years to the day after their first day of employment.

• If the employee worked for more than two years, you must retain their forms for one year after their last day of employment.

Sources

[1] Hiring Sites: definitions and overview of what hiring sites are, and the role they play in I-9

[2] Remote Examination of Documents: USCIS website outlining employer requirements if remote examination of documents (”alternative procedure”) is used

[3] Retaining Forms: information on how to retain I-9 forms, and for how long