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E-Verify ICA v32: What employers need to know

Reviewed byNina Bernardi
Published:
Key Takeaways
  • ICA v32 requires every E-Verify case to include the correct hiring site, making accurate location data essential.
  • Unconfirmed case data must be corrected by the employee in Section 1, with every change documented in the audit trail.
  • Employers must prepare for new data requirements involving automatically extended EADs and Permanent Resident Cards before March 31, 2027.

E-Verify API updates aren't usually headline news for HR teams. Most are technical or operational changes that happen behind the scenes. But the latest version of the E-Verify Interface Control Agreement (ICA v32) introduces new data requirements, more nuanced workflows, and additional complexity around how E-Verify cases are created and managed.

For employers using an integrated I-9 and E-Verify system, that means v32 isn't something to leave solely to the IT team and your vendor. Here's what employers need to know about ICA v32 and the September 2026 release.

What is E-Verify ICA?

The E-Verify ICA defines how software systems communicate with E-Verify. When an employer uses an integrated I-9 and E-Verify platform, that integration has to follow the technical and data requirements established by USCIS. When USCIS releases a new ICA version, organizations and software providers using E-Verify web services need to update their integrations to meet those requirements by the deadline they provide, or they will no longer be able to create E-Verify cases.

What does the September 2026 release mean for employers?

On September 22, 2026, E-Verify made ICA v32 publicly available to web services developers, officially starting the six-month adoption period. Web services integrations and acceptance testing must be completed by March 31, 2027. E-Verify's official announcement outlines the v32 adoption timeline and key changes.

For employers, the key questions are how their organization connects to E-Verify and who is responsible for keeping that connection compliant.

If your organization manages its own E-Verify integration, your technical, product, and compliance teams will need to evaluate the v32 requirements and determine what needs to change.

If you use an I-9 or E-Verify provider, they should handle most of the v32 implementation. Employers should still confirm how the update will roll out and whether any changes will affect their workflows.

Why does E-Verify ICA v32 matter?

The biggest change goes beyond the technical requirements. It's the level of compliance complexity and business process change that the new E-Verify integration needs to support. WorkBright CEO Chapelle Ryon detailed this in a memo a few months ago.

ICA v32 introduces new data requirements and more nuanced workflows around E-Verify cases. Systems need to collect more information than is required on Form I-9 about certain individuals and understand more about the circumstances surrounding a case, rather than just sending information already collected during the I-9 completion.

3 things employers need to know about ICA v32

ICA v32 includes several technical updates that your provider will handle behind the scenes. Three of the changes will affect how your HR team completes Form I-9 and creates E-Verify cases.

1. Every E-Verify case must be tied to a hiring site

Under v32, every E-Verify case must include a hiring site. Every employer already has at least one hiring site in its E-Verify account. The new requirement is to identify the correct hiring site for each case and send it with the case.

What this means for employers:

  • Review your hiring sites in E-Verify. Multi-location employers should confirm that each location where they hire is set up correctly in their E-Verify account.
  • Define which hiring site applies to each hire. This matters most when hiring, I-9 completion, and E-Verify case creation happen in different places, for example with remote hires or a centralized HR team.

2. Unconfirmed data must be fixed with a compliant Section 1 correction

Unconfirmed data means E-Verify could not confirm information submitted with a case, such as a name, date of birth, or Social Security number. Under v32, E-Verify will no longer allow a case to be closed and resubmitted when data is unconfirmed. The employee corrects Section 1 of Form I-9 instead, and the correction is recorded in the audit trail.

This turns a simple data-entry fix into a Form I-9 compliance step. Section 1 belongs to the employee, so the employee (or their preparer or translator) has to make the correction. The employer cannot make it for them.

ICE’s August 2026 update to its I-9 inspection guidance also says electronic I-9 systems must produce records with a compliant audit trail, and inspectors may review how a form was corrected, not only the final version.

What this means for employers:

  • Have a process to send corrections back to the employee. The case can’t move forward until the employee updates Section 1.
  • Make sure only the employee changes Section 1. HR and managers should not edit employee-provided information directly.
  • Confirm your system records every correction. The audit trail should show who changed what and when.

3. New requirements for extended EAD and Permanent Resident Card documents

If an employee presents an expired Employment Authorization Document (Form I-766) or Permanent Resident Card (Form I-551) that has been automatically extended, E-Verify will require details about the extension. That means information from the receipt notice (Form I-797 or I-797C), or the country for extensions under Temporary Protected Status (TPS) or Deferred Enforced Departure (DED).

These details are more than what Form I-9 itself asks for, so they need to be collected while the I-9 is being completed. Waiting until the E-Verify case is created can delay the case.

What this means for employers:

  • Train I-9 reviewers to recognize auto-extended documents. They should know when an expired EAD or Permanent Resident Card is still acceptable and what supporting information goes with it.
  • Collect extension details during Section 2 review. Record the receipt notice details or the TPS/DED country at the same time the document is examined.
  • Track EAD extension end dates. Reverification has to happen on time when an extension runs out.

Other v32 updates, such as the added case details (software name, hiring site location, and a remote document examination indicator) and the move to online ICA documentation, are mostly handled by your I-9 and E-Verify provider.

What should employers ask their E-Verify provider?

If you use an I-9 and E-Verify provider, ask how they're handling the specific changes introduced with ICA v32.

What is your timeline for the E-Verify ICA v32 updates?

Understand when updates will be made and how they will be communicated with customers.

What information will be added to our E-Verify case submissions?

Ask how they are planning to collect the additional information needed for hiring sites and extension documents.

Will v32 change how our team creates or manages cases?

Ask whether the new unconfirmed data requirements will change your workflow for Section 1 edits and when any changes will take effect.

What do we need to do before March 31, 2027?

Finally, ask your provider to confirm whether any action is required from your organization before the v32 adoption deadline, or whether the provider will manage the transition entirely within its integration.

How WorkBright is managing ICA v32

Our platform and services are built to manage the full I-9 and E-Verify lifecycle, and our teams continuously monitor regulatory and technical changes to keep our processes up to date.

WorkBright’s product, engineering, and compliance teams are already working through the ICA v32 requirements, updating workflows, and testing the changes needed ahead of the March 31, 2027, deadline. We’ll keep customers informed as updates are released and implementation progresses. If you have questions about ICA v32 compliance, please reach out to your WorkBright Customer Success Manager.

The big picture

ICA v32 introduces new data requirements and more sophisticated compliance considerations that will affect how E-Verify cases are created, what information is submitted with those cases, and how different document and workflow scenarios are represented.

While software providers will handle much of the technical implementation, employers still need to understand whether their current approach can support the changes and, more importantly, who will own that work.

The March 31, 2027 deadline makes it important to start those conversations now. Ask your provider what ICA v32 means for your organization, how they're implementing the changes, and who will own the compliance complexity going forward.

WorkBrightRadically simple form verification

HR compliance is complex, but it doesn’t have to be. WorkBright’s modern software and services streamline I-9s, E-Verify, and form management, while keeping your team audit-ready and aligned with ever-changing regulations. Take the guesswork out of compliance so you can focus on what matters most—your people.

Nina BernardiContent Strategy Manager

Nina has spent over seven years in the tech industry, transforming complex ideas, user insights, and industry research into content that informs and engages readers.