30-Day Comment Matrix

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I-9-018 Extension - Responses to 30-day FRN Public Comment
Public Comments (regulations.gov): USCIS-2006-0068
30-day FRN Citation (federalregister.gov): 91 FR 53629
Publish Dates: August 19, 2026 – September 18, 2026
Comment ID/Topic

Comment Summary

USCIS Response

Commenter: Anonymous
0733

DHS claims an annual out-of-pocket cost
burden of $0, reasoning that verification
activities occur naturally within hiring. This
factually indefensible calculation ignores
commercial electronic I-9 software licensing,
secure physical document storage, third-party
remote verification fees, and legal audit costs
borne by employers.

Response:
E-Verify is a free, web-based system run by the U.S.
government that allows employers to electronically
confirm the legal work eligibility of their newly hired
employees. The use of third-party remote
verification companies is not required nor is the use
of commercial electronic I-9 software. These are
voluntary costs for an employer.
Further, in the normal course of business and under
current law, a company would have secure physical
document storage for its Form I-9 documentation;
storing Form I-9s in the same manner is not an
additional cost.
While a company could be audited by ICE at any
time to confirm Form I-9 compliance, if the
company has properly completed and stored all
required Form I-9s, there should be no legal audit
costs incurred.