Form I-9 employment eligibility verification requirement
All Iowa employers must complete Form I-9, Employment Eligibility Verification, for every individual hired for employment in the United States, including both U.S. citizens and non-citizens. Employees must complete and sign Section 1 no later than the first day of employment (but not before accepting a job offer). Employers must complete Section 2 within three business days of the employee's first day of work by physically examining the employee's identity and employment authorization documents. Employers must retain each completed Form I-9 for three years after the date of hire or one year after employment ends, whichever is later.
E-Verify requirement for Iowa state agencies and Board of Regents
Iowa Executive Order 15, signed October 8, 2025, mandates that all state executive branch agencies and the Iowa Board of Regents use E-Verify to confirm the employment eligibility of every newly hired employee. E-Verify is a federal web-based system administered by U.S. Citizenship and Immigration Services (USCIS) that compares information from an employee's Form I-9 to records maintained by the Department of Homeland Security and the Social Security Administration.
Covered employers
The executive order applies to:
- All Iowa executive branch state agencies
- The Iowa Board of Regents
E-Verify obligations
State agencies subject to the order must:
- Enroll in the E-Verify system if not already registered;
- Use E-Verify to verify the employment eligibility of all new hires; and
- Maintain documentation in compliance with federal Form I-9 regulations (no additional state-specific retention requirements are imposed by the order).
The verification is performed after the employee completes Section 1 of Form I-9 and the employer completes Section 2 by examining the employee's identity and work-authorization documents. Within a few seconds, E-Verify typically confirms employment eligibility or indicates that additional information is necessary before a determination can be made.
Implementation timeline
Executive Order 15 directed state agencies to complete a memorandum of understanding (MOU) with USCIS in October 2025 and begin the user authorization process with a goal of being fully operational by the end of 2025. The Iowa Department of Administrative Services has confirmed that the State of Iowa participates in E-Verify and verifies new hires through the system within the required federal timeframe.
Scope limitation
Executive Order 15 applies only to state executive branch agencies and the Board of Regents as employers. Iowa does not require private employers or other governmental entities (cities, counties, school districts) to use E-Verify by statute or administrative rule. Federal contractors with qualifying contracts (exceeding $100,000 and longer than 120 days) remain subject to the federal E-Verify mandate under FAR clause 52.222-54 regardless of Iowa law.
Source: Gov. Reynolds issues Executive Order 15 requiring state government's use of E-Verify and SAVE
Source: E-Verify and Right to Work, Iowa Department of Administrative Services