Work Authorization Revoked Overnight: HR’s Step‑By‑Step Response Guide
What HR Teams Must Know About 2025 Work Authorization Revocations
Early 2025 policy shifts triggered mass revocations of Employment Authorization Documents (EADs) and Temporary Protected Status (TPS), leaving HR teams scrambling to reverify I‑9s, restrict access, and support affected employees.
On June 20, 2025,
E‑Verify issued guidance instructing employers to regularly generate the
Status Change Report to identify revoked EADs tied to terminated parole cases. Upon receiving these updates, employers must immediately reverify impacted employees using
Form I‑9, Supplement B.
The Problem: Rapid Revocation of Work Authorization
In Q2 2025, DHS revoked hundreds of thousands of EADs, including those tied to TPS and parole programs, triggering urgent compliance actions for HR teams.
Employers must reverify affected employees using
Form I‑9, Supplement B, while allowing continued employment until valid replacement documents are provided. Failing to act quickly can result in
penalties from $716 to $5,724 per employee.
Post-COVID compliance audits have shown that
reactive processes increase risk. And in this enforcement-heavy climate, there’s no room for delay.
What to Do: HR’s Action Plan for Reverification
- Monitor E-Verify Daily
Use the Status Change Report to stay ahead of revocations and identify affected employees. - Start Immediate Reverification
Reverify using Form I‑9 Supplement B. Accept updated List A or C documents only. Do not terminate or suspend employment prematurely. - Log Everything
Track each case with timestamps, document types, and notes for audit-readiness. - Communicate Clearly
Notify employees promptly. Explain the next steps and what documents are acceptable. - Train the Team
Ensure HR staff understand the process and timing. Assign I‑9 champions to ensure consistency across locations. - Run Internal Compliance Checks
Proactively review past forms and reverification steps to stay ahead of I‑9 audits and ICE enforcement.
Why It Matters: Compliance and Employee Trust
Prompt action helps protect both the business and your people. The risks of inaction include:
- Costly non-compliance penalties
- Increased legal exposure for unauthorized employment
- Loss of employee trust and retention challenges
Reassuring affected employees and taking fast action shows that your company values compliance and care equally.
How Clear I-9 Can Help You Stay Ahead
Clear I‑9 was built for moments like this. Our compliance solution offers:
- Automated E‑Verify Checks: Detect EAD status changes instantly
- Supplement B Wizard: Step-by-step reverification guidance
- Live I-9 Video Verifications: Complete Form I‑9 Section 2 remotely through our verified video agents
- Virtual Agent Network: Remote, compliant reverifications anywhere
- Secure Digital Storage: Built-in audit trail for ICE inspections
- Real-Time Updates: Stay aligned with DHS and ICE compliance changes
Ready to Respond with Speed, Accuracy, and Confidence?
Schedule a demo of Clear I‑9 today and discover how your HR team can stay compliant, responsive, and audit-ready—even when work authorization changes overnight.
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