Understanding I-9 and E-Verify
When you hire someone in the United States, two terms come up quickly: the I-9
Form I-9 to verify the identity and employment authorization of individuals hired for employment in the United States. and E-Verify An online system that confirms the eligibility of an Employee to work in the United States. The process compares information entered by an employer from an employee’s Form I-9, Employment Eligibility Verification, to records available to the U.S. Department of Homeland Security and the Social Security Administration to confirm employment eligibility.. They sound related, and they are, but they are not the same thing. Talent Platform completely manages the digital Form Any document that needs to be completed and signed by a Candidate I-9 process inside the platform. Your E-Verify workflow depends entirely on your specific system setup. Depending on your configuration, tasks may happen seamlessly within Bullhorn or require external logging. Understanding what each one is helps you know what to expect and where your own responsibilities come in.
The I-9 is a federal form every U.S. employer must complete for every new hire. Bullhorn natively manages this.
E-Verify is a government system that checks I-9 information against federal records. How your team interacts with it inside Bullhorn depends on your integration type:
- AbleVerify: Everything is completed directly within Talent Platform with no separate logins required.
- Integrated Partners (e.g., DISA): Most actions can be taken directly inside Talent Platform, but users maintain a separate partner login. This specific partner integration is legacy and closed to new customers.
- External Connection: If you use your own standalone E-Verify account, it is not integrated with Talent Platform. Your team can complete the I-9 in Bullhorn and manually process the case using your government portal login.
What Is the Difference?
| What you need to know | |
|---|---|
| Form I-9 | A federal form required for every person you hire to work in the U.S. The employee fills out Section 1, and you (or an authorized representative) verify their identity documents and complete Section 2. Bullhorn Talent Platform manages the entire process electronically. |
| E-Verify | A government system run by the U.S. Department of Homeland Security that checks I-9 information against federal records to confirm work authorization. Inside Talent Platform, this process is natively powered by AbleVerify, enabling automated case submission and real-time tracking directly within the E-Verify dashboard. If your organization relies on a standalone, non-integrated government account instead, your team will need to manually log into the external government portal to process every case. |
Do You Need E-Verify?
The I-9 applies to everyone who hires in the U.S., no exceptions. E-Verify is different.
E-Verify is required if your organization is a federal contractor or if your state has a law requiring it. For most other employers, it is optional. If you are not sure whether your organization uses E-Verify, your administrator or compliance team can tell you.
E-Verify requirements vary by state and employer type. This article gives you an overview, but it is not legal advice. When in doubt, check with your compliance team or visit uscis.gov/e-verify.
What Bullhorn Takes Care Of
Bullhorn provides a unified onboarding framework by driving the digital Form I-9 workflow directly inside Talent Platform. When paired with AbleVerify, this integration extends right into your E-Verify management, allowing your team to handle federal verifications without ever leaving the platform, whether your process is fully automated or manually driven.
Form I-9 Management (Available to All Users)
Talent Platform digitizes and stores the core federal requirements:
- Section 1 Delivery: Facilitates the digital delivery of Form I-9 to the new hire. Depending on your organization's configuration, this can be automated to send out or triggered manually by a recruiter.
- Section 2 Routing: Automatically alerts the designated authorized representative by email or SMS to review physical documents and sign electronically.
- Secure Document Retention: Stores the completed Form I-9 along with a compliance-ready audit trail and supports reverifications using a digital Supplement B.
For E-Verify (If Your Organization Uses It)
Talent Platform cleanly bridges your compliance data directly with the government database:
- Flexible Case Submission: Submits the case to E-Verify once Section 2 is signed, automatically if your organization uses the Auto Order system setting, or manually by the recruiter.
- Dual-Dashboard Tracking: Tracks live government case results on the E-Verify dashboard, while form completion milestones are tracked on the I-9 Dashboard 2.0.
- Status Visibility and Alerts: Flags cases requiring attention, such as a Tentative Nonconfirmation, directly within the E-Verify dashboard status view, alongside an email notification sent to the recruiter.
- Direct Resolution Steps: Surfaces the explicit federal next steps and necessary employee notice downloads directly inside Bullhorn for any case that requires follow-up.
The ability to choose between automatic and manual E-Verify submissions is available for integrated configurations, such as AbleVerify. Your administrator manages this workflow using the Auto Order system setting. If your organization relies on a standalone, non-integrated government account instead, these configuration options and in-platform dashboard submissions do not apply to your workspace.
E-Verify User Training Requirement
The federal government requires organizations that connect to E-Verify through a web services integration, and E-Verify employer agents acting on their behalf, to train every person who uses the system. This training must include a knowledge test, and users cannot access E-Verify until they pass it with a score of 70% or higher.
Bullhorn built the E-Verify Regulations & Case Management in Bullhorn Talent Platform course in Bullhorn Launch specifically to satisfy this requirement for clients using an integrated configuration, such as AbleVerify. The course covers E-Verify regulations and how case management works inside Talent Platform, and it includes the required knowledge test.
This training requirement applies to web services employers and E-Verify employer agents, which covers AbleVerify and similar integrated configurations. If your organization uses a standalone, non-integrated E-Verify account, this specific federal requirement may not apply to you the same way. Check with your compliance team to confirm which training obligations apply to your setup.
For the full federal requirements and curriculum guidelines, see Training Requirements and Guidelines for Web Services Users on e-verify.gov.
What Happens After E-Verify Is Submitted?
For organizations using integrated configurations like AbleVerify, case results feed directly back into your workspace in real time. Most of the time, the process is completely hands-off. The majority of E-Verify cases come back as Employment Authorized and close automatically.
When a case does require manual follow-up, the status updates directly on your E-Verify dashboard. Here is what the primary results mean and how they are handled:
| Result | What It Means and What to Do |
|---|---|
| Employment Authorized | The employee is confirmed as work-authorized. The case closes automatically. No action needed. |
| Verification in Process | DHS needs a little more time. Most of these resolve within 24 hours. Check back for an update. |
| Tentative Nonconfirmation (TNC) | The information did not instantly match government records. Bullhorn flags the status on your E-Verify dashboard and sends an email alert to the recruiter. The dashboard surfaces the exact required federal next steps, including the ability to send the Further Action Notice to the employee. |
| Final Nonconfirmation (FNC) | E-Verify could not confirm work authorization. The employer must close the case. You may terminate employment based on this result. |
During a government shutdown or E-Verify system outage, cases may be delayed. If this happens, Bullhorn recommends temporarily disabling the Auto Order setting to avoid a backlog. Your administrator can re-enable it once E-Verify is back online.
When Does It Need to Happen?
The I-9 and E-Verify each have their own deadlines tied to the employee's first day.
| Deadline | What Needs to Be Done |
|---|---|
| On or before the employee's first day | The employee must complete Section 1 of the I-9. |
| Within 3 business days of the first day | Section 2 must be completed by the authorized representative. For integrated configurations, such as AbleVerify, if the Auto Order system setting is enabled, the E-Verify case submits automatically at this exact time. |
| Within 3 business days of the hire date | If submitting E-Verify manually, the case should be created within 3 business days. |
Send the I-9 in Bullhorn early. Waiting until the last minute leaves no room if the employee or authorized representative is slow to complete their part.
Common Questions
We completed Section 2. Is E-Verify handled automatically?
It depends on whether your organization has Auto Order enabled. If it is on, E-Verify is submitted as soon as Section 2 is signed. If it is off, the recruiter creates the case manually from the I-9 Dashboard 2.0. Your administrator can confirm which applies to you.
Does every employee need an I-9?
Yes. Every person hired to work in the U.S. needs one, regardless of how large or small your organization is. Independent contractors are generally exempt, but employees are not.
Can we review documents remotely instead of in person?
Yes, if your organization is enrolled in E-Verify. USCIS allows enrolled employers to use the Alternative Procedure for remote document inspection. If you are not enrolled, documents must be reviewed in person.
What do we do if an employee gets a Tentative Nonconfirmation?
Bullhorn notifies the recruiter and displays the required next steps in the I-9 Dashboard 2.0. You can then send the Further Action Notice directly within Talent Platform. The employee then decides whether to contest the result. You cannot take adverse action against the employee while the case is pending.
Where can I learn how to complete an I-9 in Bullhorn?
See I-9 Process for step-by-step instructions. If your organization uses E-Verify, see the E-Verify User Training Requirement section above for required training.
Scenarios
The following scenarios describe common situations where understanding the difference between I-9 and E-Verify matters. Each scenario is written to stand alone so it can be matched to your question directly.
Scenario: A recruiter asks whether completing the I-9 in Bullhorn means E-Verify is done.
When a recruiter completes Section 2 of the Form I-9 in Bullhorn, the I-9 requirement itself is satisfied. However, whether E-Verify is automatically triggered at that point depends entirely on your integration and system configuration:
- Integrated Setups (such as AbleVerify): If your administrator has the Auto Order system setting turned on, Bullhorn automatically submits the case data to E-Verify the moment Section 2 is signed. If Auto Order is turned off, the recruiter must manually click to submit the case from within the platform. In both instances, everything stays inside Bullhorn. No external government login is required.
- Standalone Accounts: If your organization relies on a non-integrated government account, the processes are entirely separate. Completing the form in Bullhorn does not trigger E-Verify. The recruiter must copy the I-9 data from Bullhorn, manually log into the external government portal, and create the case there.
Scenario: A new hire's first day is tomorrow and the I-9 has not been started.
The employee must complete Section 1 of the I-9 on or before their first day of work. If the I-9 has not been assigned yet, the recruiter should send it in Bullhorn immediately. Section 2 must be completed within 3 business days of the employee's first day. If Auto Order is enabled, Bullhorn submits the E-Verify case automatically when Section 2 is signed.
Scenario: A client asks why they need an I-9 even though they are a small staffing agency.
The Form I-9 is federally mandated for all U.S. employers regardless of company size or industry. There is no minimum employee count. Any organization hiring individuals to work in the United States must complete a Form I-9 for every new hire. Bullhorn Talent Platform simplifies this compliance requirement electronically, handling everything from the initial request delivery to secure digital retention and a comprehensive, compliance-ready audit trail.
Scenario: An employer wants to use remote document inspection but is not sure if they are allowed to.
Remote document inspection using the Alternative Procedure is only permitted for employers enrolled in E-Verify and in good standing with the program. If the organization is not enrolled, documents must be reviewed in person. To enable it in Bullhorn, an administrator must turn on the Enable Alternative Procedure checkbox in Company Settings > System Settings > Form I-9 and E-Verify.