Understanding authorized representatives on the Form I-9

Last updated: November 4, 2026

This explains who can complete Section 2 of the Form I-9 on your behalf, how Onboarded decides whether an authorized representative is an option, and what stays your responsibility either way.

What it is

Section 2 of the Form I-9 is the employer's half. Someone examines the employee's identity and work authorization documents, records them, and signs the certification. That someone doesn't have to work for you. USCIS lets you designate an authorized representative, any person you choose, such as a notary, a personnel officer, or a member of the general public, to examine the documents and complete Section 2 for you.

In Onboarded, a setting on each employer decides whether a representative is an option. When one is used, the employee passes their representative a link, and the representative completes Section 2 from it.

If you remember nothing else: the representative does the review, but the I-9 is still yours. You're liable for any violation connected to the form, including ones the representative commits.

Why it matters

Section 2 is due within three business days of the employee's first day of work, and the documents generally have to be examined with the employee physically present. When no one from your team can be in the room in that window, an authorized representative is how Section 2 gets done on time.

This matters most when:

You hire people who live far from any of your locations.
You place workers at sites where no one from your team works.
You're choosing between representatives and the DHS alternative procedure for remote document review.

How it works

The employer setting decides who reviews

Who completes Section 2 is set per employer, not per form, with the I-9 Section 2 Review Designation attribute (employer.i9_section_2_review_option). It has three values:

Setting	What the employee sees on the `Section 2 Review Method` page
`Employer review only`	A confirmation that their employer will examine documents and complete Section 2. There's no choice to make.
`Authorized representative review only`	Instructions for using a representative, plus a link and QR code to pass to that person.
`Employer review and authorized representative review available`	A choice between `My employer will review and complete Section 2` and `An authorized representative will review`.

Because the setting lives on the employer, an account with several employers can allow representatives for some and not others.

How the handoff works

The employee completes Section 1, then reaches Section 2 Review Method. When a representative is used, the page gives the employee a link and QR code to send them. The representative opens it, examines the employee's original documents with the employee present, records them, and signs the Section 2 certification with their own title.

The employee has to submit the Section 2 Review Method page before the representative can start. If a representative says the link isn't working, check whether the employee finished that page.

What doesn't change

Original documents, examined in person. Copies and photos don't count as physical examination. The one remote exception is the DHS alternative procedure, which is only open to employers in good standing in E-Verify. In Onboarded it's a separate employer setting, I-9 Alternative Document Review Procedure (employer.i9_remote_doc_examination).
The three-business-day deadline. It applies whoever completes Section 2.
Employees can't represent themselves. An employee can't complete, correct, or attest to Section 2 of their own I-9.
No notary seal. A notary acting as a representative signs Section 2 but doesn't stamp the form.

How it shows up for your team

Section 2 is employer work, so Onboarded classifies the representative's step as an employer step, even though someone outside your team completes it. Tools that show task status will show it that way too.
If you run E-Verify as its own form, the E-Verify task shows a waiting message until the representative submits Section 2, then switches to case creation.
When the representative finishes, the I-9 task moves to completed and the PDF is generated as usual.

Example

Take an account that hires remote customer service agents in 30 states and has offices in two of them. The HR Engineer sets the employer's I-9 Section 2 Review Designation to Employer review and authorized representative review available.

A new hire in Montana completes Section 1, reaches Section 2 Review Method, and picks An authorized representative will review. She submits the page and texts the link to a notary at her bank. On her first day she brings her U.S. passport to the bank. The notary examines it in person, records it, and signs Section 2 without a seal.

In Onboarded, the I-9 completes and the separate E-Verify task picks up the Section 2 data. The HR team spot-checks the I-9 PDF, since any error the notary made is still the account's to own, and creates the E-Verify case that afternoon, well inside the three-day window.