Can an I-9 be completed before the new employee’s first day?

  • Yes. After offer acceptance you may complete the I-9 in Edison.
  • If the employee does not have Edison access, the Agency I-9 Coordinator would need to complete the Paper or Special Case I9v.
    • If the employee already has Edison access, you may have the employee complete Section 1 after offer acceptance.
  • You may complete Section 2 early (after offer acceptance and Section 1) if you have examined the employee’s acceptable original documents; just make sure you still meet the Day-3 rule.
  • For E-Verify, the system allows creating a case before the start date (up to 90 business days in advance).

Counting days: “First day of work for pay” is the hire date. The three-business-day clock excludes the hire date and follows normal business days (generally Monday–Friday, excluding federal holidays).

Practical tips for pre-boarding:

  • If you start the record early, double-check the start date before submitting the E-Verify case; if the start date later changes, you can’t edit the hire date in E-Verify after submission (update the date on the Form I-9 instead)
  • Ensure that you correct the fake EMPLID as soon as the permanent EMPLID is available and instruct the employee not to complete the paperless I-9 to avoid duplicate I-9s being completed.

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