Staffing agencies may complete Form I-9 once an employee accepts an offer and is in an assignment pool. The acceptance date is used as the employee’s first day of employment on Form I-9 and in E-Verify. Can the certification date be left blank until they are placed?

Staffing agencies should not leave the certification date or the Employee’s First Day of Employment field blank. When completing Section 2 of Form I-9, staffing agencies may choose to use either the date a new employee is assigned to their first job or the date a new employee accepts an offer and is entered into the assignment pool as the first day of employment. USCIS recommends that staffing agencies remain consistent with regard to the date they choose to use as the first day of employment when completing Forms I-9 and E-Verify cases.

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