This overview provides employers with updated guidance for completing, updating, and reverifying Form I-9 for employees who present Temporary Protected Status (TPS) documentation, including recent court-ordered extensions, automatic EAD extensions, and TPS terminations.
TPS Terminations
For employers with employees affected by TPS termination, the employer must complete reverification and may not continue employment unless affected employees provide alternate proof of valid work authorization.
| Country | Status | Summary |
| Burma (Myanmar) | Terminated | EADs with category codes A12 or C19 issued under these TPS designations are no longer valid. |
| El Salvador | Automatic EAD extensions | Eligible TPS beneficiaries from El Salvador may continue to present qualifying EADs and USCIS extension notices through Sept. 9, 2026. |
| Ethiopia | Court-ordered extension | TPS-related employment authorization were extended through August 19, 2026 with special Form I-9 completion instructions and court-order references required in the Additional Information field. |
| Haiti | Terminated | EADs with category codes A12 or C19 issued under these TPS designations are no longer valid. |
| Lebanon | Automatic EAD extensions | TPS beneficiaries from Lebanon with qualifying A12 or C19 EADs have automatic work authorization extended through Nov. 27, 2026, and must be reverified before Nov. 28, 2026. |
| Somalia | Court-ordered extension | TPS-related employment authorization were extended through August 14, 2026 with special Form I-9 completion instructions and court-order references required in the Additional Information field. |
| South Sudan | Terminated | EADs with category codes A12 or C19 issued under these TPS designations are no longer valid. |
| Syria | Terminated | EADs with category codes A12 or C19 issued under these TPS designations are no longer valid. |
| Venezuela | Retained under limited circumstances | Certain Venezuelan TPS beneficiaries retain TPS or employment authorization under limited circumstances, primarily based on approval dates, I-94 issuance dates, or qualifying EAD renewal applications. Employers should carefully review documentation due to the complexity of the Venezuela TPS litigation and differing eligibility scenarios. |
| Yemen | Terminated | EADs with category codes A12 or C19 issued under these TPS designations are no longer valid. |
Action Items
- Review employee records to identify individuals working under TPS-based employment authorization.
- Update Form I-9 records for employees impacted by TPS extensions using the country-specific instructions provided.
- Initiate reverification for employees affected by TPS terminations or upcoming expiration dates.
- Ensure employees are given the opportunity to present any valid alternative work authorization documents.
- Escalate complex cases, particularly Venezuela TPS matters and employees with pending applications or alternative immigration statuses, for additional review.
Recommendations
- Conduct a targeted audit of TPS-related I-9 records to confirm proper documentation and reverification tracking.
- Review upcoming reverification deadlines and establish proactive outreach to affected employees.
- Consult immigration counsel for cases involving litigation-related extensions, pending benefits, or nonstandard documentation.
- Continue monitoring USCIS and Form I-9 updates as TPS-related policies and litigation remain subject to change.
Vijay Thakkar has more than 12 years of HR Operations experience, including 8 years helping employers improve their Form I-9 management and E-Verify compliance, especially for mergers & acquisitions, internal and external I-9 audits, training and development, migration to the electronic system, I-9 escalations, quality checks, strategic planning, and building standard operating procedures with a keen interest in US immigration and global mobility.
Prior to joining Experian, Thakkar has served as Levi Strauss & Co’s I-9 subject matter expert, an investigator to the behavioral health unit at the US Army, and Sustainability Analyst at his alma mater the University of Texas at Arlington from where he earned his Master’s in Human Resource Management and MBA.
