December 1, 2025

E-Verify Program Policy And Procedures

Raj Singh, NCASEF Treasurer

7-Eleven, Inc. may take the position that under the 7-Eleven franchisee agreement, franchisees may be required to provide certification regarding wages, hours, and the eligibility of their employees to work in the United States, and pay the cost of outside auditors to verify the accuracy of the certification. We are required to register and use E-Verify for new hires or rehires. Please see below the processes of how to enroll in E-Verify, how to use E-Verify for new hires and rehires, and the consequences if we don’t do use this service.

 

  1. Overview

E-Verify is a secure, web-based system operated by the U.S. Department of Homeland Security (DHS) in partnership with the Social Security Administration (SSA). The program allows employers to electronically verify the employment eligibility of newly hired employees and certain rehires.

7-Eleven is required by the federal government to participate in E-Verify. This requirement helps ensure that all employees are legally authorized to work in the United States and that the company remains fully compliant with federal employment laws.

 

  1. Enrollment and Account Setup

Step 1: Visit www.e-verify.gov.

Step 2: Click “Enroll in E-Verify.”

Step 3: Complete the online enrollment form with the company’s legal information, Employer Identification Number (EIN), and contact details.

Step 4: Review and accept the DHS Memorandum of Understanding (MOU).

Step 5: Once approved, the company will receive a User ID and temporary password.

Step 6: Complete the required online training to activate the account.

Step 7: Assign user roles and ensure only trained, authorized individuals have access.

 

  1. Verification for New Hires

Federal regulations require that E-Verify cases be created no later than the third business day after the employee’s start date.

 

Process:

  1. Complete Form I-9 (Employment Eligibility Verification) on or before the employee’s third day of work.
  2. Log in to the E-Verify system.
  3. Select “New Case.”
  4. Enter employee information exactly as it appears on Form I-9.
  5. Submit the case for verification.
  6. Review the system response:
    • Employment Authorized: No further action is required.
    • Tentative Non-Confirmation (TNC): Inform the employee immediately and follow E-Verify procedures to resolve.
    • Final Non-Confirmation: If unresolved, the case must be closed according to federal guidelines.
  7. Document and close the case in the E-Verify system.

 

  1. Verification for Rehires

If an employee is rehired within three years of the date of their previous Form I-9:

  • The employer may use the existing Form I-9 if still valid, or complete a new one if information has changed.
  • Log in to E-Verify and create a new case for the rehire.
  • Follow the same steps as for a new hire.
  • Ensure any changes in work authorization are updated on Form I-9.

 

  1. Employer Responsibilities
  • Do not use E-Verify to pre-screen job applicants.
  • Use E-Verify only after the employee has accepted a job offer and completed Form I-9.
  • Apply E-Verify procedures consistently for all new hires.
  • Protect the confidentiality of employee information at all times.
  • Retain Form I-9 and E-Verify records according to federal retention rules.
  • Follow required procedures if a TNC or Final Non-Confirmation is issued.

 

  1. Training and Compliance

All employees who use E-Verify must complete mandatory DHS online training before accessing the system. Ongoing compliance checks will be conducted to ensure that:

  • E-Verify cases are created in a timely manner.
  • Documentation is accurate and properly retained.
  • All actions are in accordance with federal employment verification laws.

 

  1. Additional Resources
  • E-Verify Official Website: https://www.e-verify.gov
  • E-Verify Employer Hotline: 1-888-464-4218
  • E-Verify Email: e-verify@uscis.dhs.gov
  • USCIS Form I-9 Information: https://www.uscis.gov/i-9

 

  1. Summary

E-Verify is a critical part of our hiring and onboarding process. By following these procedures, our organization complies with federal law, protects the integrity of our workforce, and ensures that all employees are legally authorized to work in the United States.

 

Consequences of Not Using E-Verify for Hiring or Rehiring

While E-Verify is voluntary for many employers at the federal level, it is mandatory for certain industries, federal contractors, and in several states. Failing to use E-Verify where required—or failing to verify employment eligibility properly—can expose employers to significant legal, financial, and reputational consequences.

 

  1. Legal and Regulatory Consequences
  2. I-9 Non-Compliance

Even if E-Verify isn’t mandatory, all U.S. employers must complete Form I-9 for every new hire. Not using E-Verify does not relieve employers of this obligation. If an employer hires an unauthorized worker and did not use E-Verify (when required or recommended), it can be seen as negligence or willful disregard of federal immigration laws.

 

  1. State and Federal Penalties

Certain states (such as Arizona, Alabama, Mississippi, and others) require employers to use E-Verify. Non-compliance in these states can result in:

  • Suspension or revocation of business licenses.
  • Fines or penalties.
  • Ineligibility for state contracts or incentives.

If the employer is a federal contractor with an E-Verify clause, failure to use E-Verify can lead to contract termination or suspension from future federal projects.

  1. Financial Consequences
  2. Civil Fines

Hiring unauthorized workers, whether intentional or accidental, can result in substantial fines from U.S. Immigration and Customs Enforcement (ICE). These fines escalate based on the number of violations and whether they are repeat offenses.

  1. Increased Audit Costs

If an employer is found to have hired unauthorized workers without proper verification, the business may be subjected to audits, investigations, and compliance reviews. Legal fees and operational disruptions add indirect financial burdens.

  1. Reputational Damage
  2. Public Exposure

ICE often publishes enforcement actions, including employer names, leading to public embarrassment and reputational harm. Customers, clients, or investors may lose trust in an organization that fails to comply with employment verification laws.

  1. Loss of Business Relationships

Vendors or partners who require proof of compliance may sever ties with non-compliant employers. Some clients—especially in government, infrastructure, or security sectors—require strict hiring compliance as a condition for doing business.

  1. Hiring and Workforce Risks
  2. Risk of Workforce Disruption

If unauthorized workers are discovered after hiring, employers may be forced to terminate employees immediately. This can lead to staffing shortages, halted operations, and negative impacts on productivity.

  1. Increased Scrutiny

Failure to use E-Verify, especially after prior violations, may flag the employer for ongoing monitoring by DHS or ICE, which can trigger repeated inspections.

  1. Consequences for Rehiring Without E-Verify

Rehiring employees presents additional risks:

  • If an employer fails to reverify a previously terminated employee’s work authorization when rehiring after certain timeframes, it risks harboring unauthorized workers.
  • If an employee’s status has changed or expired, rehiring without using E-Verify (or updating Form I-9) contributes to non-compliance and potential liability.

 

Key Takeaway

Even where E-Verify is not mandatory, using it demonstrates a good-faith effort to comply with federal immigration law. Employers that choose not to use E-Verify risk:

  • Legal penalties
  • Civil fines
  • Business license loss
  • Contract termination
  • Public reputational damage

 

Best Practices for Employers

  • Use E-Verify whenever possible, even if optional.
  • Train HR personnel on I-9 and E-Verify procedures.
  • Keep accurate records of verification efforts.
  • Stay updated on federal and state E-Verify requirements.

By proactively using E-Verify, employers build a stronger legal defense, maintain ethical hiring standards, and protect their business from serious consequences.