Can a Voter Registration Card Be Used as a List B Document for Form I-9?

Yesterday, one of my clients, Sarah, reached out with an important Form I-9 compliance question:

"Elga, I have a new hire presenting a Voter Registration Card as a List B document, but Voter Registration Cards do not have a picture. Can I accept it?"

This is a great question and one that HR professionals must fully understand to ensure compliance with employment eligibility verification laws. The short answer is yes, a Voter Registration Card can be accepted as a List B document, but there’s an important exception—E-Verify employers cannot use it for photo matching.

Understanding List B Requirements

The Form I-9 List B documents establish identity, while List C documents establish employment authorization. According to the USCIS Handbook for Employers (M-274), a Voter Registration Card is listed as an acceptable List B document—meaning it can be used to verify a new hire’s identity. Unlike other List B documents, such as a driver’s license or state-issued ID, a Voter Registration Card does not require a photo. Instead, it must include other identifying information such as name, date of birth, gender, height, eye color, and address.

The E-Verify Exception

While a Voter Registration Card may be acceptable for Form I-9 verification, it cannot be used by E-Verify employers for identity verification. E-Verify requires that any List B document presented must contain a photograph to allow for proper photo matching within the system. If an employer participates in E-Verify, they must request an alternative List B document that includes a photo, such as a state-issued ID, driver’s license, or school ID card with a photograph.

What Should Employers Do?

If your company does not use E-Verify, you can accept a Voter Registration Card as a List B document as long as the new hire also provides a List C document (such as a Social Security card or birth certificate) to establish employment authorization. However, if your company is enrolled in E-Verify, you must request a different List B document that includes a photo to comply with photo-matching requirements. Do not ask the employee for a specific document; instead, provide them with the List B options so they can choose which to present.

Stay Compliant with Our Form I-9 Training

With increased scrutiny on I-9 compliance and potential fines for errors, HR professionals must stay up to date on employment verification laws. To help you navigate these complex requirements, we offer a Complete 4-Hour Form I-9 Certificate Program for Employment Eligibility Verification. This program provides in-depth training on proper I-9 completion, document verification, and compliance best practices.

Check our website for upcoming dates and times:

htps://hrtrainingclasses.com/product/complete-4-hour-form-i-9-certificate-program-for-employment-eligibility-verification/

Elga Lejarza

Founder & CEO

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