On June 20, 2025, the U.S. Department of Homeland Security (DHS) announced a change in how E-Verify will manage the termination notification of employees with Employment Authorization Documents (EADs) that have been revoked. E-Verify is a system that compares information entered by an employer from an employee’s Form I-9, Employment Eligibility Verification, to records available to the DHS and the Social Security Administration to confirm employment eligibility. Enrollment in E-Verify is voluntary for most employers except for certain federal contractors, and employers seeking to employ students in F-1 STEM OPT status. It is also mandatory by some states (e.g., Arizona, Florida, Tennessee and Utah).
Recently, DHS ended the removal protections and employment authorization for thousands of individuals covered by Temporary Protected Status and parole programs. Initially, E-Verify notified employers of the terminated EADs through Case Status Alerts. Now, employers will be required to actively monitor the status of their employees by generating the newly released Status Change Report. This report replaces the use of Case Status Alerts and will be regularly updated.
The new Status Change Report allows E-Verify employers or their employer agents to review their aggregated case data for any employees who presented an EAD for employment verification which has now been revoked by DHS. This change will have an immediate impact on employers who hired those individuals now present in the United States through the parole programs for Cubans, Haitians, Nicaraguans and Venezuelans (CHNV).
What to Do
To access the new report, employers need to login to their E-Verify account and click on the “Reports” tab at the top of the homepage to select the Status Change Report. The chart will display dates that EADs were revoked by DHS.
If an employer’s report identifies individuals with revoked EADs, the employer must reverify each employee using Form I-9. Keep in mind, an employee may still be employment authorized based on another status or provision of law and may provide other acceptable Form I-9 documentation to demonstrate employment authorization. The reverification is completed using Supplement B of Form I-9 and the employer must accept any valid List A or List C document.
An employer should not create a new E-Verify case as the reverification process must be completed through the Form I-9 procedures. We emphasize employers should not accept revoked EADs even if they appear unexpired.
Reverification should be conducted in a timely manner and be well documented.
Risks for Employers
Employers are legally required to ensure that every individual on their payroll is authorized to work in the United States. The use of invalid or revoked EADs, knowingly or unknowingly, can expose employers to significant legal liability, including potential audits and fines from the Department of Labor or Immigration and Customs Enforcement (ICE).
The consequences of failing to review the Status Change Report regularly may be deemed to be knowingly employing individuals who are not authorized to work. Moreover, the Status Case Report includes the date the information became available in the E-Verify system. It is the government’s position that an employer must act within a reasonable length of time to address the notification. Failure to act on a revoked EAD, due to a lapse in monitoring or through improper reverification, may result in a worksite enforcement action. Employers who fail to comply with I-9 and E-Verify laws may face civil and criminal penalties per violation, including monetary fines and imprisonment.
Employers are reminded to proceed with caution when reverifying employment as the Immigration and Nationality Act prohibits you from treating individuals differently on the basis of national origin, citizenship, or immigration status in the Form I-9 or E-Verify processes. Therefore, the reverification of employees whose EADs were revoked must be conducted carefully and in accordance with all applicable Form I-9 regulations.
Conclusion
While DHS has designed the Status Change Report to assist employers in identifying employees with terminated EADs, it has also created yet another compliance measure that can expose an employer to violations and liabilities. Employers need to update their best practices policy by adding the new Case Status Report tool to their list of internal verification processes. Failure to manage this new procedure could result in unwelcomed attention from DHS.
If you need any assistance in navigating the new Status Change Report process, , please contact the authors or any attorney with Frost Brown Todd’s Immigration Group.