On June 20, 2025, the Department of Homeland Security (“DHS”) issued an Employment Authorization Document (“EAD”) revocation guidance for E-Verify employers. The guidance put E-Verify employers on notice that they have access to a new E-Verify tool, a “Status Change Report” (the “Report”). The Report identifies employees whose EADs have been revoked by DHS. DHS had been sending impacted workers notices of their EAD revocations, including their obligation to return their EADs to DHS, and leave the U.S.
However, not all workers were notifying their employers about EAD revocations. Now, employers have been given constructive notice of EAD revocations through the Report. The Report allows E-Verify employers to review their aggregate case data for any employee whose EAD has been revoked by DHS. The Report contains the document revocation date, case number, and A-number for each affected individual. The report will be “regularly updated” as DHS revokes EADs.
EAD revocations may be announced for individual employees or as a group, including for Cuban, Haitian, Venezuelan, and Nicaraguan (CHNV) parolees. Once an employer receives a Status Change Report, the employer must use Form I-9, Supplement B, to reverify the impacted individual’s employment authorization. Employers must also reverify employees who voluntarily disclose to their employer that their EAD has been revoked.
All reverifications must be completed “within a reasonable amount of time.” Although DHS has not defined the timeframe the agency considers “reasonable,” relying on the 10 federal government working days to resolve Tentative Non-Confirmations in E-Verify seems a safe bet.
The Report is available under the “Reports” tab and replaces Case Status Alerts. Employers must follow up on all case alerts and case status in the Status Change Report in E-Verify and reverify each employee on Form I-9 if their EAD was revoked. Employers are cautioned against terminating affected employees without giving them an opportunity to provide alternative Form I-9 List A, or List B and C documentation because employees listed in the Report may still be authorized based on another status or provision of law.
Employers should not continue to employ any worker not authorized to work in the U.S. and should expect continued heightened I-9 and E-Verify enforcement activity by ICE for the foreseeable future. Now is an excellent time to conduct Form I-9 audits and training if employers have not done so already.
For more information, please contact a member of Benesch’s Immigration Practice Group.