Form I-9 rehire or acquisition log: 8 suggested fields

Form I-9 rehire record: the short answer on what to log

A Form I-9 rehire or acquisition record holds eight suggested fields: the hire date, the prior Form I-9 date, the three-year check, and the acquisition option. U.S. Citizenship and Immigration Services states that you must complete a new Form I-9 when a hire takes place, unless you are rehiring an employee within three years of the date the employee’s previous Form I-9 was completed. This three-year line is the primary decision point for your rehire record. If the previous form is older than three years, you treat the individual as a new hire for verification purposes. If it is newer, the rehire exception may apply, so you can consider reusing the prior form.

The eight fields listed in the title cover both the timeline and the suggested tracking choices for these events. Field one is the current date of hire. Field two is the completion date of the prior Form I-9. Field three records whether the rehire occurs within that three-year window. For acquisitions, field four captures the choice between treating employees as new hires or continuing their employment status. The remaining fields address corrections, name mismatches, unit transfers, and E-Verify consistency. These entries create a clear audit trail for why a new form was or was not completed.

Key takeaways

• Three-year rehire check: Compare the prior Form I-9 completion date with the new hire date ( U.S. Citizenship and Immigration Services).
• Option A for acquisitions: Treat all acquired employees as new hires and complete a new Form I-9 for each one ( U.S. Citizenship and Immigration Services).
• Option B for acquisitions: Keep the previous owner’s Form I-9 for each acquired employee who continues uninterrupted ( U.S. Citizenship and Immigration Services).
• Liability for prior errors: Under Option B, you are liable for errors or omissions on the previously completed form ( U.S. Citizenship and Immigration Services).

The fields from the hire and the prior form

Capture the current date of hire and the completion date of the previous Form I-9 to establish the timeline for the rehire check. According to U.S. Citizenship and Immigration Services, an agent designated to complete and maintain Form I-9 must enter the employee’s date of hire each time the employee is hired by an employer of a multi-employer association.

Record the termination date alongside the hire date when applicable, since the same source describes entering the date of termination for those agents. Logging both dates creates a clear record of the employment period that ended before the rehire occurred. When you prepare the rehire record, place the new hire date in the field assigned to the current engagement. Then locate the prior Form I-9 and extract the date it was completed during the previous tenure.

The three-year rehire check depends on comparing these two dates. If the gap between the prior form's completion date and the new hire date falls within three years, the rules may allow you to skip a new form. However, if the gap exceeds three years, a new Form I-9 is generally required. By recording both dates accurately at the outset, you create the necessary data points to make this determination without ambiguity.

If you cannot locate the prior Form I-9, note the absence in your internal logs and proceed with the new form as standard practice. The focus here is on capturing the documented dates that exist. Once these two fields are filled, you have the foundation needed to evaluate whether the rehire triggers additional verification steps. Keep the original documents separate but cross-referenced by employee ID to maintain clarity across multiple tenures.

Illustrative example: a rehire one year later

Suppose an employee's previous Form I-9 was completed one year before the rehire date. Enter the new hire date and that prior completion date in the first two fields. The gap falls within three years, so the rules may allow you to skip a new form. Enter yes in the third field and note the result in your log. If the gap were longer than three years, a new form would be required.

The fields for acquisitions and unit transfers

When you inherit employees through an acquisition or move staff between distinct units, the mechanics depend on whether you treat them as new hires or continuing employees. U.S. Citizenship and Immigration Services outlines two specific options for acquired staff: Option A treats everyone as a new hire, while Option B retains the previous owner's forms for those with uninterrupted employment status. You choose one path, and an internal log helps show which set of documents governs each individual’s file.

For distinct unit transfers within the same employer, you may transfer the employee’s existing Form I-9 to the receiving unit rather than completing a new form. This applies specifically when moving from one distinct unit to another distinct unit of the same employer. If you are dealing with a successor, related, or reorganized employer, you can maintain continuing employment records provided you obtain and maintain the previous employer’s Forms I-9 where applicable. These distinctions determine whether you enter a new date or reference an old one in your tracking system.

The table below maps the eight suggested log fields to their actions under each option. Some rows restate USCIS rules, while others are suggested internal tracking steps.

Under Option A, when you complete the new form, enter the effective date of the acquisition or merger as the employee’s first day of employment in Section 2 of that new form. This date entry is a required step in the new document creation process. In contrast, Option B requires you to retain the previous owner’s Form I-9 for each acquired employee who continues their uninterrupted employment status. You do not create a new form under this option; instead, you verify that the prior documentation exists and remains in your possession.

The choice between these options affects how you handle the paperwork for every individual in the acquired group. If you select Option A, every person receives a fresh form with the acquisition date logged as their start date. If you select Option B, you rely on the historical forms provided by the previous entity. Your record should clearly state which option was chosen for the entire batch, since each option applies to all acquired employees. Ensure your internal notes reflect this decision so future audits can trace why a particular date appears in Section two or why an older form is present in the file.

The fields for corrections and name differences

When you choose Option B to keep prior forms, your internal log can note any fixes made to those documents. Because you are liable for errors on that form, as noted above, your rehire log could include a field listing every correction applied to the acquired employee’s document. The guidance states that you and/or the employee should make any corrections to the acquired employee’s existing Form I-9. Record the nature of each fix in this field so the file reflects the current state of the paperwork rather than just the original submission date. For detailed procedures on how to execute these changes, the source directs readers to Section 9, Correcting Errors or Missing Information on Form I-9. Cite that section number in your notes if you need to reference the specific protocol used for the update. This ensures the audit trail shows not just that a form exists, but that its known defects have been addressed according to the cited handbook instructions.

Field source reference table by publisher

The rules and definitions below come from three government publishers. Each row names the rule, the publisher that states it, and the title of the source page where you can verify the language. Use this table to confirm which agency issued a specific instruction before you record your decision on the rehire or acquisition log.

The blank rehire and acquisition record

Copy the layout below into each rehire or acquisition file to capture the eight suggested fields. Include corrections made, any document name mismatch, distinct unit transfer details, and an E-Verify consistency note. For reverification specifics, see 6.0 Completing Supplement B, Reverification and Rehire (formerly Section three) of Form I-9, as noted by U.S. Citizenship and Immigration Services. Use this layout on one rehired employee today, and fill the hire date and prior Form I-9 date first.

Related guides: Check a green card or EAD on Form I-9 in 3 steps · Verify new hires in 4 steps: Form I-9 and E-Verify · Criminal record requests: 5 steps to choose a source.

FAQ: Form I-9 rehires and acquired employees

What fields go on a Form I-9 rehire record?

A rehire record holds eight suggested items: the hire date, the prior form date, the three-year check, the option chosen, corrections made, any name mismatch, unit transfer status, and an E-Verify note. These fields capture the timeline for the rehire decision and the specific administrative choices you make during the process. Use this structure to ensure each decision point is documented clearly.

Do I need a new Form I-9 when I rehire someone?

You must complete a new form unless you are rehiring an employee within three years of the date their previous form was completed, according to U.S. Citizenship and Immigration Services. If the rehire happens after that three-year window has passed, a new form is required. Check the completion date on the old form before deciding whether to start a new one.

Can I transfer a Form I-9 between units of the same employer?

Yes, you may transfer the employee’s Form I-9 to the receiving unit if they move from one distinct unit to another distinct unit of the same employer, according to U.S. Citizenship and Immigration Services. Verify that both locations qualify as distinct units before moving the document.

What do I enter when the document name differs from the Form I-9 name?

Record this discrepancy as part of your documentation review when the employee's name in the presented documentation differs from the name listed on the form. Note the difference clearly so it is visible during any future audit or review.

Does an acquisition always require new Form I-9s?

It depends on the option you choose for the acquired staff. Option A treats all acquired employees as new hires and requires a new Form I-9 for every individual, while Option B retains the previous owner’s forms, according to U.S. Citizenship and Immigration Services. Selecting Option B means keeping the existing forms for each acquired employee who continues in uninterrupted employment. Your choice determines whether new paperwork is generated for the entire group.