Written by: Don Lori, Alexander Medrak, and Celine Malnash[1]
On August 26, 2025, E-Verify released a new set of circulating questions (FAQS) and extensive directives about canceling employment licensing documents (EADS) issued under the human conditional release programs.
New common questions for E-Verify can be found here.
Fast summary: What has changed since July
As I mentioned earlier, the Ministry of Internal Security (DHS) began nullifying EADS for individuals whose conditional release was ended for the conditional release, the most prominent of which was those who were released in light of the CHNV operations (Cuba, Haiti, Nicaragua, and Venezuela). Initially, employers adopted Case alerts To identify the affected employees. This system has now retired in favor of Case change reportWhich provides more detailed and implementable data, including cancellation dates, cases numbers and numbers.
August update: common questions and new clarifications
August 26Y The update adds a layer of clarity to the employers who are still struggling with the discretionary obligations. The title of the recently published questions:
- How to explain the case change report
- When and how to score using the supplement b
- What do you do if Ead seems to the employee in effect, but it was listed as canceled
- How to deal with reverence without violating the anti -discrimination laws
Employers are reminded that even if Ead appears valid on her face, she must do so no It is accepted if it is included in The case of changing the caseR. Instead, employees must be recorded and alternative documents, from the A menu or menu C of the I-9 document lists.
EAD timeline
| EAD has been canceled for the history employee* | Date information available in the electronic status change report |
| From April 9 to August 19, 2025 | August 26, 2025 |
| From April 9 to August 5, 2025 | August 12, 2025 |
| April 9 to July 24, 2025 | July 29, 2025 |
| April 9 to July 8, 2025 | July 15, 2025 |
| April 9 to June 13, 2025 | June 20, 2025 |
Uscis is directed about what employers need to know
- Direct notifications from the Ministry of National Security: The Ministry of National Security sent notifications to non -employees who were released in the United States that the Ministry of National Security was ending the conditional release and aimed at canceling EAD based on the conditional release.
- Regular monitoring of the E-Verify: The case change report is frequently updated with the identification of E-Verify stating that it will be updated almost every two weeks. Labor employers must check this routinely to stay compatible.
- EADS: EADS employees may still have EADS have documents that look fit for face and non -scattered. However, if the card number is inserted into the Verify Change Report, the employers should not accept the document during the veneration. Likewise, when creating E-Verify for New Hirs, employers who seem to be valid but lead to preliminary assertion (TNC) due to the cancellation of the basic employment license.
- Use the B from the I-9 Form: Do not complete a new i-9 or create a new electronic clarification case upon estimate.
- Keep aware: Check here to get the full list of common questions for employers regarding the cancellation of the conditional release.
Interestingly, E-Verify also provided instructions to employers’ agents regarding companies whose customers are no longer.
Your next steps
Online employers should behave in all alerts and inputs in the report of changing the electronic status through the mission of any current employee canceled. Although the abolished EAD cannot be accepted, the employee may remain dependent on work under a different situation and can provide other valid documents to show the continuous recruitment qualification.
What about non -young employers? A critical gap in guidance
While employers have received detailed instructions, including access to Case change report The updated common questions are still the non -rival employers in the dark. The Ministry of National Security did not issue any official guidelines for employers who do not participate in the electronic examination, which leaves a large compliance gap.
This lack of instructions excites fate in particular because:
- There is no central mechanism for non -displaced employers to identify employees who have been canceled on the conditional release.
- The government is not currently tracking where these individuals are employed if their employers are not registered in Vertife.
- No proactive alerts or reports preparation tools have been provided to help non -contestant employers meet their appreciation obligations.
This creates a double -flat compliance system. E-Verify is expected to act quickly based on DHS data. Uninterrupted employers are left without tools or instructions, which increases the risk of unintended violations or discriminatory practices.
In order for DHS clear instructions, employers are not established:
- Watch closely with any employees ’contacts regarding the changing condition of the conditional humanitarian release.
- Consult the legal advisor before taking any action related to repetition.
- Avoid putting assumptions on a citizenship -based work permit or setting a conditional humanitarian release to survive compatible with anti -discrimination laws.
Other employers are facing additional risks during the ICE and Customs audits (ICE). Without reaching Case change reportThey may keep employees who are unacceptable to be uncomfortable who are now lacking work. Although we believe it will be difficult for ICE to impose sanctions without proving knowledge, we are watching this area carefully.
You should consult the legal advisor on how to move forward as well as ensure compliance with the requirements of the I-9 and E-Verify. For more information, contact your SEYFARTH or Dawn Lurie’s relationship. The SEYFARTH Group for Specialized Compliance and Enforcement – recognized as national leaders in this field – is trusted by Fortune 100 companies in addition to small companies across the country to obtain strategic and practical advice. The collection provides comprehensive guidelines on the i-9 and E-Verify compliance, ICE inspections, work enforcement procedures, internal immigration assessments, I-9 audits, DEL wage and migration investigations, public trips/ITAR, and DOJ-ER antifook, including external care and declaration control/ITAR.
[1] Selene Malench is a compliance writer in the SEYFARTH team. Thank you very much for her contribution to this blog post.