On August 11, 2026, E-Verify expanded its Status Change Report to include additional categories of invalidated Employment Authorization Documents (EADs). The report previously covered certain parolee EADs in category C11. It now also includes invalidated EADs issued under the following categories:
- C08: Asylum applicant with a pending asylum application
- C09: Adjustment of status applicant under INA § 245
- A12: Individual granted Temporary Protected Status (TPS)
- C19: TPS applicant
- C11: Parolee EADs, which were already included
The expansion affects employer Form I-9 compliance, E-Verify monitoring, and employment authorization reverification procedures. The U.S. Department of Homeland Security (DHS) will update the report approximately every two weeks as additional information becomes available. Employers should review the official E-Verify bulletin and establish a regular internal review process.
What the Status Change Report Identifies
The Status Change Report identifies E-Verify cases that were created using an EAD later invalidated by DHS. An EAD may appear unexpired on its face even though DHS has withdrawn its validity. DHS generally does not collect previously issued cards. Therefore, possession of an apparently valid card does not necessarily establish current employment authorization.
The report includes information such as:
- E-Verify case number
- Employee A-number
- EAD revocation or invalidation date
- Revoked Document Number, which corresponds to the EAD card number
The card number is essential. Employers should not take action merely because an employee’s name or case appears in the report. The employer must first review the employee’s existing Form I-9 and compare the card number recorded on the form with the Revoked Document Number in the report.
If the numbers match, the EAD used for Form I-9 and E-Verify has been invalidated. The employer must begin reverification. If the numbers do not match, the EAD used for the employee’s Form I-9 is not the document identified in the report. In that circumstance, reverification is not required until the employee’s employment authorization normally expires.
Why DHS May Invalidate These EADs
The legal basis for invalidation depends on the EAD category and the underlying immigration benefit.
C08 Asylum-Based EADs
DHS may invalidate a C08 EAD following the withdrawal, approval, or denial of the underlying Form I-589, Application for Asylum and for Withholding of Removal.
An employer must not independently determine whether an asylum applicant remains eligible for employment authorization based only on general information, news reports, or the employee’s immigration history. The employer should rely on the applicable E-Verify report information, the existing Form I-9, and any valid documentation presented during reverification.
C09 Adjustment-of-Status EADs
A C09 EAD is generally issued to an applicant with a pending Form I-485, Application to Register Permanent Residence or Adjust Status, under INA § 245. DHS may invalidate the EAD when the underlying adjustment application is withdrawn, approved, or denied.
Approval of Form I-485 may result in the employee obtaining lawful permanent resident status and presenting different employment authorization documentation. A denial or withdrawal may eliminate the basis for the C09 EAD, although the employee may have another independent basis for employment authorization.
A12 and C19 TPS-Based EADs
A12 and C19 EADs are connected to Temporary Protected Status. DHS may invalidate these documents following the termination of the TPS designation for the relevant country, subject to applicable procedures and legal developments.
TPS designations and terminations can change through federal agency action, court orders, and litigation. Some country-specific TPS terminations may be subject to ongoing judicial review or temporary injunctions. Employers must confirm the current designation and applicable employment authorization rules before making an employment decision.
Employers should monitor the E-Verify What’s New page and official USCIS TPS information for country-specific updates.
Required Employer Response When an EAD Matches the Report
An E-Verify employer must follow a structured process when the employee’s EAD appears in the Status Change Report and the card number matches the EAD used for Form I-9.
1. Review the Existing Form I-9
Before contacting the employee, review the existing Form I-9 and determine:
- Which document the employee presented during the original verification
- Whether the document was recorded as an EAD
- The EAD card number recorded in Section 2 or the applicable supplementary documentation
- Whether the employee has already been reverified using another valid List A or List C document
- Whether the employee remains actively employed
There is no reverification obligation for a former employee who no longer works for the company. If the employee was recently reverified with another valid document, the employer generally does not need to reverify again until that authorization expires.
2. Use Form I-9 Supplement B
The employer must use Form I-9, Supplement B, Reverification and Rehire. The employer should begin the process promptly and complete it within a reasonable amount of time after learning that the EAD was invalidated.
The process is an update to the existing Form I-9. It is not a new hire verification process.
3. Request Unexpired List A or List C Documentation
The employee must present unexpired documentation establishing current employment authorization. The employee may choose either:
- One unexpired List A document establishing identity and employment authorization; or
- One unexpired List C document establishing employment authorization, together with an existing List B identity document
The employer must not require the employee to present a specific document. The employer may not demand a new EAD, a particular immigration document, or the same document the employee presented previously.
The invalidated EAD must not be accepted for reverification, even if its printed expiration date has not passed.
4. Do Not Reverify List B Identity Documents
Reverification concerns employment authorization only. Employers must not reverify List B identity documents and must not request new identity documentation as part of this process.
An employer that asks for additional or different documents based on the employee’s nationality, citizenship, immigration status, or appearance may create discrimination exposure under the Immigration and Nationality Act.
5. Do Not Create a New E-Verify Case
Employers must not create a new E-Verify case for reverification resulting from an invalidated EAD. The employer must document the reverification on Form I-9 Supplement B.
Creating a new E-Verify case can produce an incorrect workflow, duplicate records, or an unnecessary tentative nonconfirmation. It does not replace the required Form I-9 reverification procedure.
Discrimination and Consistency Risks
Employers must apply the same procedures to similarly situated employees. The employer should establish a written process that specifies:
- How often the Status Change Report will be generated.
- Which personnel will review the report.
- How card-number matches will be confirmed.
- How employees will be contacted.
- How much time employees will receive to present acceptable documentation.
- How the company will document each action.
The company should use consistent deadlines and communication methods. It should not reverify only employees who appear foreign, speak with an accent, come from a particular country, or hold a particular immigration classification.
The employer must allow each affected employee to choose acceptable documentation. It must not reject documents that reasonably appear genuine and relate to the person presenting them.
A documented, neutral process reduces the risk that an otherwise lawful reverification procedure will be characterized as discriminatory.
Non-E-Verify Employers Have Less Visibility
Employers that do not participate in E-Verify do not receive Status Change Report entries. They may have no automated visibility into whether an EAD previously used for Form I-9 has been invalidated by DHS.
However, the underlying Form I-9 obligations still apply. If a non-E-Verify employer receives reliable information that an employee’s employment authorization has been revoked, including through a DHS notice or the employee’s voluntary disclosure, the employer must evaluate whether reverification is required.
The employee may have another basis for employment authorization. The employer must provide the employee an opportunity to present acceptable List A or List C documentation. The employer should not assume that the invalidation of one EAD means the employee lacks all employment authorization.
Do Not Rely on ICE Enforcement Activity Alone
ICE enforcement activity, workplace operations, detention, or immigration arrests do not by themselves establish that an employee has lost work authorization.
Detention does not necessarily mean that an individual’s employment authorization has been revoked. An individual may have employment authorization through a separate immigration status, a pending application, a valid document not connected to the enforcement action, or another provision of law.
Employers must not terminate or suspend an employee solely because the employee was detained, arrested, questioned, or identified in an ICE enforcement action. Employment decisions must be based on reliable information concerning current employment authorization and must follow the Form I-9 process.
Recommended Compliance Actions for Employers
E-Verify employers should take the following steps:
- Generate the latest Status Change Report regularly.
- Review all active employees identified in the report.
- Compare each Revoked Document Number with the EAD card number recorded on the existing Form I-9.
- Reverify only when the numbers match or when the employer otherwise receives reliable information that the EAD was invalidated.
- Use Form I-9 Supplement B.
- Request unexpired List A or List C documentation.
- Do not reverify List B identity documents.
- Allow employees to choose their acceptable documents.
- Do not create a new E-Verify case.
- Confirm current TPS country designations and litigation-related developments.
- Apply the same procedures and timeframes consistently.
- Preserve documentation showing how the company reviewed and resolved each report entry.
Employers should also incorporate these procedures into their broader internal I-9 audit program and business immigration compliance policies.
Contact Blasingame Law LLC
The August 2026 Status Change Report expansion creates new operational responsibilities for E-Verify employers. Errors in card-number matching, document requests, TPS analysis, or reverification timing can result in employment disruption, discrimination claims, and government compliance exposure.
Blasingame Law LLC provides experienced guidance on Form I-9 compliance, E-Verify procedures, workforce audits, TPS-related employment authorization, and business immigration matters. Contact Blasingame Law LLC to schedule a consultation regarding your organization’s reverification procedures or workforce compliance program.
This article provides general information and does not constitute legal advice. Employers should obtain legal guidance for specific employees, TPS designations, litigation developments, or suspected EAD invalidations.
