On August 26, 2025, E-Verify released a new set of Frequently
Asked Questions (FAQs) and expanded guidance on the revocation of
Employment Authorization Documents (EADs) issued under humanitarian
parole programs.

E-Verify’s new FAQs can be found here.

A Quick Recap: What’s Changed Since
July

As previously reported, the Department of Homeland Security
(DHS) began revoking EADs for individuals whose parole had been
terminated, most notably those paroled under the CHNV processes
(Cuba, Haiti, Nicaragua, and Venezuela). Initially, employers
relied on Case Alerts to identify affected employees. That
system has now been retired in favor of the Status Change
Report, which provides more detailed, actionable data
including revocation dates, case numbers, and A numbers.

August Update: New FAQs and Clarifications

The August 26th update adds a layer of clarity for
employers still grappling with reverification obligations. The
newly published FAQs address:


How to interpret the Status Change Report

When and how to reverify using Supplement B

What to do if an employee’s EAD appears valid but is listed
as revoked

How to handle reverification without violating
anti-discrimination laws

Employers are reminded that even if an EAD appears valid on its
face, it must not be accepted if it is listed in
the Status Change Report. Instead, employees must be
reverified and present alternative, unexpired documentation from
List A or List C of the Form I-9’s Lists of Acceptable Documents.

EAD Revocation Timeline




Date Employee’s EAD Was Revoked*
Date Information Available in E-Verify Status Change
Report



April 9 to Aug. 19, 2025
Aug. 26, 2025



April 9 to Aug. 5, 2025
Aug. 12, 2025



April 9 to July 24, 2025
July 29, 2025



April 9 to July 8, 2025
July 15, 2025



April 9 to June 13, 2025
June 20, 2025

USCIS Instructs on What Employers Need to
Know


Direct Notifications from DHS: DHS sent notifications to
noncitizens who were paroled into the United States that DHS was
terminating their parole and intended to revoke their parole-based
EADs.

Monitor E-Verify Reports Regularly: The Status Change Report is
updated frequently with E-Verify stating that it will be updated
approximately every two weeks. Employers should check it routinely
to stay compliant.

Revoked EADs: Employees whose EADs have been revoked may still
possess documents that appear facially valid and unexpired.
However, if the Card Number is listed in the E-Verify Status Change
Report, employers must not accept the document during
reverification. Similarly, when creating E-Verify cases for new
hires, employers may encounter EADs that look valid but trigger a
Tentative Nonconfirmation (TNC) due to the underlying revocation of
employment authorization.

Use Supplement B of Form I-9: Do not complete a new I-9 or
create a new E-Verify case when reverifying.

Stay informed: Check here for the full list of employer FAQ
regarding parole-based revocations.

Interestingly, E-Verify also provided guidance to Employers
Agents regarding companies that are no longer their customers.

Your Next Steps

E-Verify employers must act on all alerts and entries in the
E-Verify Status Change Report by reverifying any current employee
whose EAD has been revoked. While the revoked EAD cannot be
accepted, the employee may still be authorized to work under a
different status and can present other valid documentation to
demonstrate continued employment eligibility.

What About Non–E-Verify Employers? A Critical Gap
in Guidance

While E-Verify employers have received detailed instructions,
including access to the Status Change Report and updated
FAQs, non–E-Verify employers remain in the dark. DHS has not
issued any formal guidance to employers who do not participate in
E-Verify, leaving a significant compliance gap.

This lack of instruction is particularly concerning because:


There is no centralized mechanism for non–E-Verify
employers to identify employees whose parole-based EADs have been
revoked.

The government does not currently track where these individuals
are employed if their employers are not enrolled in E-Verify.

No proactive alerts or reporting tools have been made available
to help non–E-Verify employers meet their reverification
obligations.

This creates a two-tiered system of compliance. E-Verify
employers are expected to act swiftly based on DHS data.
Non–E-Verify employers are left without tools or guidance,
increasing the risk of inadvertent violations or discriminatory
practices.

Until DHS provides clear instructions, non–E-Verify
employers should:


Closely monitor any communications from employees regarding
humanitarian parole status changes.

Consult legal counsel before taking any action related to
reverification.

Avoid making assumptions about work authorization based solely
on nationality or humanitarian parole status to remain compliant
with anti-discrimination laws.

Non-E-Verify employers face added risk during Immigration and
Customs Enforcement (ICE) audits. Without access to the Status
Change Report, they may unknowingly retain employees with
revoked EADs who now lack work authorization. While we believe it
will be difficult for ICE to impose penalties without proof of
knowledge, we are watching this area carefully.

Legal counsel should be consulted on how to move forward as well
as ensure compliance with Form I-9 and E-Verify requirements. For
more information contact your Seyfarth relationship attorney or
Dawn Lurie directly. The Seyfarth Immigration Compliance &
Enforcement specialty group–recognized as national leaders in
the field—is trusted by top Fortune 100 companies as well as
small businesses across the country for strategic, practical
advice. The group offers comprehensive guidance on Form I-9 and
E-Verify compliance, ICE inspections, and worksite enforcement
actions, internal immigration assessments, I-9 audits, DOL
immigration-related wage and hour investigations, general H-1B
compliance, and DOJ-IER anti-discrimination matters, including
foreign sponsorship and export control/ITAR issues.

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.