Employers Must Begin Using Standard Form I-9 in Commonwealth of the Northern Mariana Islands

Beginning on November 28, 2011, employers hiring individuals for employment in the Commonwealth of the Northern Mariana Islands (CNMI) must begin using the standard ‘Form I-9, Employment Eligibility Verification’ for all new hires and reverifications in the CNMI, according to a page titled “Form I-9 Guidance for Employers Hiring Individuals in the Commonwealth of the Northern Mariana Islands” on the U.S. Citizenship and Immigration Services (USCIS) web site.

According to the USCIS web site:

On Nov. 28, 2009, the Immigration and Nationality Act (INA) and other Federal immigration laws took effect in the Commonwealth of the Northern Mariana Islands (CNMI), as provided by the Consolidated Natural Resources Act of 2008.  As a result, since Nov. 28, 2009, CNMI employers have been required to verify the identity and employment authorization of their new hires as required under U.S. law.  Employers in the CNMI are subject to the same civil fines and criminal penalties for Form I-9 violations as U.S. employers.

From Nov. 28, 2009 until Nov. 27, 2011, employers used Form I-9 CNMI rather than the standard Form I-9 to verify the identity and employment authorization of their new hires.  Form I-9 CNMI is the same as the standard Form I-9, with one exception:  Form I-9 CNMI contains additional List A documents issued by the CNMI government that are not acceptable on the standard Form I-9.  These additional documents are only acceptable until Nov. 27, 2011. 

By Nov. 28, 2011, all workers who previously held CNMI-issued employment authorization must have another basis of work authorization under U.S. law, or have a petition pending for CNMI-only transitional worker status as described below, to continue working in the CNMI. 

Employers hiring individuals for employment in the CNMI may only use Form I-9 CNMI until Nov. 27, 2011.  Beginning on Nov. 28, 2011, employers must use the standard Form I-9 for all new hires and reverifications in the CNMI.


The U.S. Citizenship and Immigration Services (USCIS) is the government agency that oversees lawful immigration to the United States. The Commonwealth of the Northern Mariana Islands (CNMI) occupies the western Pacific Ocean and is in political union with the United States. Under the union, in general, U.S. federal law applies to CNMI.