My company has several divisions and affiliates. When determining which new and existing employees must be verified in E-Verify, does it matter if my affiliates are separate legal entities for tax purposes?

Only the legal entity (business) that signs the contract is considered the contractor, and is bound by the E-Verify obligation. Whether certain subsidiaries and affiliates are a part of a legal contracting entity depends on the specific factual context. Consult your legal representative and government contracting official if you have additional questions about these topics. For information about verifying your existing workforce if you are a federal contractor with a contract that contains the FAR E-Verify clause, see the E-Verify Supplemental Guide for Federal Contractors.