Mixing and Matching Your Way to I-9 Compliance

What Are I-9 List B and C Documents? A Quick Answer for Busy HR Teams

I-9 List B and C documents are two categories of acceptable documents used to complete Form I-9, the federal form required to verify every new hire’s identity and right to work in the United States.

Here’s the fast answer:

List	Purpose	Examples
List B	Proves identity only	Driver’s license, state ID, school ID with photo, military card
List C	Proves work authorization only	Social Security card (unrestricted), birth certificate, Native American tribal document

Key rule: An employee can present either one List A document (which covers both identity and work authorization on its own), or one document from List B plus one from List C together.

So if your new hire hands you a driver’s license and a Social Security card, that’s a valid List B + List C combination and you’re good to go for Section 2 of Form I-9.

Ever since the Immigration Reform and Control Act (IRCA) was passed in 1986, U.S. employers have been legally required to verify the identity and employment eligibility of every person they hire. That means every new hire, every time, no exceptions.

For HR managers juggling onboarding, payroll, and a dozen other priorities, the I-9 process can feel like a compliance minefield. Which documents count? Can you ask for a specific one? What happens when something expires?

This guide breaks it all down in plain language, so you can move fast and stay fully compliant.

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Understanding the Basics of I-9 List B and C

When we talk about the Form I-9, we are really talking about solving a two part puzzle. To hire someone legally in the United States, we must prove two things: who they are (identity) and that they are allowed to work here (employment authorization).

List A documents are the “all in one” solution. A U.S. Passport or a Green Card proves both identity and authorization at the same time. However, many employees do not have these or prefer not to use them. That is where i9 list b and c come into play.

According to the Form I-9 Acceptable Documents | USCIS guidelines, if a List A document is not provided, the employee must provide one document from List B and one from List C. It is a “mix and match” system. You can learn more about this in our Navigating I-9: A Comprehensive Guide to Acceptable Documents resource.

Feature	List B Documents	List C Documents
Primary Goal	Establishes Identity	Establishes Work Authorization
Visual Requirement	Usually contains a photo	Usually a paper certificate or card
Must be paired?	Yes, with a List C document	Yes, with a List B document
Example	State Driver’s License	Unrestricted Social Security Card

The Complete Catalog of Acceptable List B Identity Documents

List B is all about making sure the person standing in front of you is who they claim to be. For most adults, this is a photo ID issued by a government authority.

Here is the full list of acceptable unexpired List B documents:

1. Driver’s license or ID card issued by a State or outlying possession of the United States, provided it contains a photograph or information such as name, date of birth, gender, height, eye color, and address.
2. ID card issued by federal, state, or local government agencies or entities, provided it contains a photograph or identifying information.
3. School ID card with a photograph.
4. Voter’s registration card.
5. U.S. Military card or draft record.
6. Military dependent’s ID card.
7. U.S. Coast Guard Merchant Mariner Card.
8. Native American tribal document.
9. Driver’s license issued by a Canadian government authority.

For a deeper dive into recording these in Section 2, check out our I-9 Section 2 Acceptable Documents Guide.

Special Provisions for Minors Using I-9 List B and C

What happens if you hire a 16 year old who does not have a driver’s license or a school ID? The USCIS provides special “alternative” List B documents for minors under the age of 18 who cannot produce a standard identity document. These include:

• School records or report cards.
• Clinic, doctor, or hospital records.
• Day-care or nursery school records.

If a minor uses one of these, the employer must still pair it with a standard List C document, such as a birth certificate or Social Security card.

Navigating List C Employment Authorization Requirements

Once you have established identity with List B, you need to confirm the person is legally allowed to earn a paycheck. List C documents establish employment authorization only.

The most common List C documents include:

1. An unrestricted Social Security Account Number card.
2. Certification of report of birth issued by the Department of State (Forms DS-1350, FS-545, FS-240).
3. Original or certified copy of a birth certificate issued by a State, county, municipal authority, or territory of the United States bearing an official seal.
4. Native American tribal document.
5. U.S. Citizen ID Card (Form I-197).
6. Identification Card for Use of Resident Citizen in the United States (Form I-179).
7. Employment authorization document issued by the Department of Homeland Security (DHS).

It is worth noting that Puerto Rico birth certificates must have been issued on or after July 1, 2010, to be valid for I-9 purposes. Older versions were invalidated by the Puerto Rican government to combat fraud.

Common Restrictions for I-9 List B and C Social Security Cards

The Social Security card is the “go to” List C document, but not every card is created equal. To be a valid List C document, the card must be unrestricted.

If the card has any of the following notations, it cannot be used for List C:

• “NOT VALID FOR EMPLOYMENT”
• “VALID FOR WORK ONLY WITH INS AUTHORIZATION”
• “VALID FOR WORK ONLY WITH DHS AUTHORIZATION”

If an employee presents a card with these notes, they likely need to provide a different List C document or a List A document (like an Employment Authorization Document, Form I-766). Additionally, the Social Security Administration advises against laminating cards because lamination can hide security features. If a card is so heavily laminated that you cannot tell if it is genuine, you may have to ask for a different document.

Rules for Employers: Handling Receipts and Reverification

Sometimes, life happens. An employee loses their wallet or their birth certificate gets damaged in a move. In these specific cases, the “Receipt Rule” applies.

A receipt is acceptable temporarily if:

1. The employee applied for a replacement of a lost, stolen, or damaged document.
2. The receipt is for the arrival portion of Form I-94 with a temporary I-551 stamp.
3. The receipt is for the departure portion of Form I-94 with a refugee admission stamp.

The 90-Day Rule: A receipt for a replacement document is valid for 90 days. By the end of that period, the employee must show the actual original document. You can find more details on handling these situations in our Expired I-9 Documents Complete Guide.

Compliance Best Practices and Retention Rules

Staying compliant is about more than just looking at cards. It is about timing and record keeping.

• The Three Day Rule: You must complete Section 2 of Form I-9 within three business days of the employee’s first day of work. If they start Monday, Section 2 must be finished by Thursday.
• Anti-Discrimination: You cannot tell an employee which documents to bring. If they want to bring a passport (List A), you cannot demand a driver’s license (List B) instead. This is called “document abuse” and can lead to heavy fines.
• Retention: You must keep a Form I-9 for either three years after the date of hire or one year after employment is terminated, whichever is later.

For a step-by-step walkthrough of the form, see our Completing I-9 Section 2 Guide.

Frequently Asked Questions about I-9 List B and C

Can employers specify which List B or List C documents employees must present?

Absolutely not. This is one of the most common mistakes employers make. The law is very clear: the choice belongs entirely to the employee. As long as the documents they provide are on the official lists and appear to be genuine, you must accept them. Forcing an employee to provide a specific document, like a Social Security card when they have already provided a birth certificate, can be considered a discriminatory practice.

Do List B identity documents require reverification if they expire?

No. This is a bit of a “gotcha” in the regulations. While all documents must be unexpired at the time of hire, List B identity documents never require reverification. If a driver’s license expires two years into an employee’s tenure, you do not need to ask for a new one. Only certain List A or List C documents that show temporary work authorization require reverification using Supplement B.

What are the retention requirements for Form I-9 after using List B and C documents?

We recommend a simple “3 or 1” rule. Keep the form for three years after the hire date or one year after the person leaves your company. Whichever date is further in the future is your target. In the event of an audit, having these organized and accessible is your best defense against penalties.

Keeping Your Workforce Compliant

Managing i9 list b and c documentation doesn’t have to be a headache. While the rules are specific, they are designed to ensure a fair and legal workplace. By understanding the difference between identity and authorization, respecting the employee’s right to choose their documents, and keeping tight records, you protect your business from costly errors.

At Valley All States Employer Service, we specialize in taking the weight of workforce eligibility off your shoulders. We provide expert, impartial, and efficient E-Verify processing to ensure your team is compliant from day one. Whether you are dealing with complex “combination documents” for nonimmigrants or just need to streamline your standard onboarding, we are here to help.

Ready to simplify your compliance process? Let us handle the details so you can focus on growing your business. Contact our team today to learn more about our outsourced E-Verify and I-9 services.