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US Citizenship and Immigration Services (USCIS) initially deployed the Status Change Report on June 20, 2025, to help certain employers identify whether any E-Verify cases were created using an Employment Authorization Document (EAD) that has since been revoked by the Department of Homeland Security (DHS). As of July 15, the report now includes a new field: "Revoked Document Number." This addition allows employers to directly compare the EAD used for Form I-9 with the revoked document listed in the report.
If the EAD used to create the E-Verify case matches the revoked number, then reverification is required.
For more information, USCIS has published updated guidance on the EAD Revocation Guidance for E-Verify Employers page and USCIS' What's New page.
What Employers Should Do Now
If you have current employees who appear on the Status Change Report, follow these steps:
- Compare the EAD number used for the Form I-9 with the Revoked Document Number in the report.
- Do not create a new E-Verify case.
- Act based on the match status, as outlined below:
| IF | THEN | AND |
| The employee's EAD used for Form I-9 matches the Revoked Document Number | The EAD is revoked | Reverify the employee using Form I-9, Supplement B with a different acceptable List A or C document |
| The employee's EAD used for Form I-9 does not match the Revoked Document Number | The EAD is not revoked | No action is required until the employee's current work authorization expires |
Questions from the Field
Q. What if an employer notices an employee who was originally on the report no longer appears on the report?
A: USCIS has explained to companies that the data report posted on June 20, 2025 had initially included employees who possessed an EAD card which had been revoked, although in some cases, they had presented a different card during the employment verification process. USCIS updated the report on July 15, 2025, to only include cases where the now-revoked EAD was used for their Form I-9, and the report now includes the card number.
Q:And conversely, what if an employer notices that additional employees have been added to the report?
A: In an interesting twist that affected some of our clients, USCIS has shared that the data report originally posted to E-Verify accounts on June 20, 2025 had initially only included E-Verify cases where the employer selected an EAD as the List A document type. USCIS updated the report on July 15, 2025 to add cases when the employee presented a now-revoked EAD, but the employer had incorrectly selected "Permanent Resident Card" instead of EAD as the document type.
Note: This is a good reminder that Form I-9 completers need to carefully review I-9 data before transmitting it to E-Verify. E-Verify may still clear someone with the wrong document selected but with the correct A number and card number. Bottom line: Do not rely in E-Verify in the I-9 context to catch errors or certain identity document issues.
Q: Does an employer need to reverify their employee who appears in the Status Change Report when the employee claims their EAD has not been revoked?
A: Employers should compare the Revoked Document Number field listed in the Status Change Report to the card number listed on the employee's EAD that was used to create their E-Verify case. If the employee's EAD card number matches the revoked document number listed in the report, then the employer must reverify the employee using Supplement B. If the employee's EAD card number is different than the revoked document number listed in the report, then the employer does not need to reverify until the employee's employment authorization expires.
Q: Should an employer act if their employee originally presented a C11 EAD and is from one of the four CHNV countries, but whose case does not appear on the Status Update Report?
A: If the case does not appear on the Status Update Report, it's possible that the employee was paroled through a different process than CHNV, and their EAD may still be valid. Work with you counsel to better understand this scenario if you have further questions. However, if the employee shows the employer documentation from USCIS that their EAD was revoked, the employer should reverify the employee even if they do not appear on the report.
Key Takeaways
- Act quickly: Pull the updated Status Change Report to assess your workforce.
- Review carefully: Match EAD numbers to determine if reverification is necessary.
- Memorialize your Actions. Keep copies of the Status Change Report and your actions.
- Stay compliant: Follow USCIS guidance and avoid creating new E-Verify cases for affected employees. USCIS' updated guidance includes a note on the need to avoid discrimination during the Form I-9 or E-Verify processes, including during the reverification process for cases with case alerts for employees whose EAD has been revoked.
This update underscores the importance of proactive I-9 compliance and monitoring E-Verify developments. If you have questions about reverification procedures or how to interpret the Status Change Report, contact the authors to learn more about our Compliance offerings.
For more information contact your Seyfarth relationship attorney or Dawn Lurie directly. The Seyfarth Immigration Compliance & Enforcement specialty group–recognized as national leaders in the field—is trusted by top Fortune 100 companies as well as small businesses across the country for strategic, practical advice. The group offers comprehensive guidance on Form I-9 and E-Verify compliance, ICE inspections, and worksite enforcement actions, internal immigration assessments, I-9 audits, DOL immigration-related wage and hour investigations, general H-1B compliance, and DOJ-IER anti-discrimination matters, including foreign sponsorship and export control/ITAR issues.
We will continue to monitor developments and provide timely updates.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
