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Completing The I-9 Without A Social Security Number

My staff member has applied for a social security number but has not received it yet. Can they still complete the I-9?

Yes, the WorkBright Form I-9 can be completed without having a Social Security Number. The employee will select the “I don’t have an SSN yet, but I have applied for it” checkbox when initially completing their profile.

Once the employee has entered and confirmed all of their personal information and indicated that they have applied for their SSN upon first signing in, they will see the "Attention: Awaiting SSN" alert at the top of their dashboard.

The employee can choose to begin their I-9. If they have selected to submit the Social Security Card, they will want to upload a copy of the receipt they received when applying for their card. When they begin the document verification process, they will want to upload a copy of the receipt and select the issuing authority.

The receipt cannot be verified, as we do not currently verify receipts. The window will change and then present the option to select ‘I’m Submitting a Receipt’. Click this to move to the next step.

They will need to select the “My document was lost, stolen, or damaged, and this is a receipt for a replacement.” checkbox. They will enter their SSN and the date the receipt expires. If the receipt does not show an expiration date, enter 90 days from the staff member's Start Date.

When they finish the I-9, the employee will receive a notification that they have indicated on their profile that they have applied for a Social Security Number. Once they receive their SSN, the employee enters it on their Form I-9 through a dedicated page. Section 1 of Form I-9 must be completed by the employee, so this is the only way the SSN can be entered on the form.

The employee will log in and click the link on their forms page (or the link in the reminder notification) to open the Update Your SSN page. On that page, they will enter their SSN and confirm the disclaimer, which explains that they are providing their SSN, that it will update their Form I-9, and that it will be sent to E-Verify where applicable.

After the employee confirms both their SSN and the disclaimer, WorkBright will:

  • Re-render their current Form I-9 submission PDF with the SSN included

  • Add the SSN to their profile

  • Submit the case to E-Verify for accounts using E-Verify, if the case is now submittable

The employee’s submission will be displayed in the Needs Attention section under Alerts on the Dashboard.

You will also see them in the “Awaiting SSN’ tab in the I-9 Forms Inbox under Onboarding.

Admins can also request a remote reverification, which notifies the employee to upload new supporting documents, including their Social Security card. This process facilitates updated requirements for profile information.

To update their profile with the new SSN, they need to log in and navigate to the Profile & Settings tab via the 'click here' link on their dashboard, or by clicking their name in the top right and selecting Profile & Settings.

From there, they will want to scroll down to the SSN portion, uncheck the box, enter their new SSN, and click "update profile" to save the change.

When the SSN is added, the I-9 will re-render to include the new SSN. If the I-9 has been completed and countersigned, and the receipt box has been checked, an E-Verify case will not be created. You will want to follow the receipt workflow here to submit it to E-Verify. If the receipt box has not been checked, the I-9 will submit a case to E-Verify and return a Submission Error (missing SSN). When the SSN is updated, it will update the E-Verify case and return a status from there.

Additionally, USCIS guidelines require an authorized representative to verify new documents, such as a Social Security card, even if prior verification was completed with other documents. This ensures compliance with employment verification requirements. If an I-9 form has been previously completed but needs to be updated with a newly obtained SSN, the recommended approach is to request a new I-9 form. Reopening Section 1 to add the SSN and redirecting the previously completed Section 2 for remote completion is not supported. Starting a new I-9 form ensures compliance and avoids potential errors.

You can also make edits to section 2 if you need to edit the documentation or the SSN. Click here for instructions on how to make edits to section 2.

If the "Request Remote Reverify" option is missing, it may be because the employee has already been reverified three times, reaching the reverification limit. In such situations, you must initiate a new Form I-9 for the employee rather than attempt another reverification.

What administrators can and cannot do

An administrator cannot enter a deferred SSN on Form I-9. Editing the SSN on the staff profile, editing Section 2, or updating the SSN through the API on the employee record will no longer re-render the Form I-9 or send the case to E-Verify. Only the employee completing the Update Your SSN page will do that.

If a staff member has given you their SSN directly, direct them to log in and complete the SSN page. If they are unresponsive, resend the reminder notification from their profile.

E-Verify behavior

If the I-9 has been completed and countersigned, and the receipt box has been checked, an E-Verify case will not be created. You will want to follow the receipt workflow to submit it to E-Verify. If the receipt box has not been checked, the I-9 will submit a case to E-Verify and return a Submission Error (missing SSN). When the employee completes the Update Your SSN page, the E-Verify case will be updated, and a status will be returned.

If you need to edit the documentation recorded in Section 2, see Editing Section 2 of the I-9. Note that Section 2 edits cannot be used to add or change the Section 1 SSN.

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