My Teen Has No Photo ID. What Can They Use for Form I-9?

By Jenna Hale · Last checked September 28, 2026

Short answer

A teenager under 18 with no photo ID can usually still complete Form I-9. If they cannot show a List B identity document, federal rules accept a school record or report card, a clinic, doctor or hospital record, or a day-care or nursery school record instead. If they have none of those either, a parent or legal guardian can establish identity for them on the form, and the teenager then only needs a List C document such as an unrestricted Social Security card or a certified birth certificate. The parent route is not available at employers that use E-Verify.

The short answer

Yes, a teenager with no driver’s license, state ID or passport can usually still get through Form I-9. The federal rule at 8 CFR 274a.2 has two fallbacks written specifically for people under 18.

Form I-9 is the federal form every employer uses to verify a new hire’s identity and permission to work. It is separate from any state work permit. If your state requires one of those, see work permits for minors.

How the document lists work

The employee picks the documents, not the employer. According to the USCIS Handbook for Employers, an employee can present either:

one document from List A, which proves identity and work authorization together, such as a US passport or passport card, or
one document from List B, which proves identity, plus one from List C, which proves work authorization.

The handbook says the employer cannot specify which documents the employee brings, and must accept documents that reasonably appear genuine and relate to the person. Documents must be originals and unexpired. The one copy that is allowed is a certified copy of a birth certificate.

Identity (List B) for a teenager

The standard List B documents on the USCIS acceptable documents page include a state driver’s license or ID card, a school ID card with a photograph, and a military dependent’s ID card, among others.

For a person under 18 who cannot present any of those, the same page and the regulation accept these instead:

a school record or report card
a clinic, doctor or hospital record
a day-care or nursery school record

The regulation labels these “acceptable to establish identity only,” so they fill the List B slot and nothing more. A List C document is still needed alongside.

When there is no identity document at all

If a teenager has no List B document and none of the three under-18 substitutes, a parent or legal guardian can establish identity for them. The USCIS handbook section on minors sets out the steps:

The parent or guardian completes Section 1 of Form I-9 and enters “Individual under age 18” in the signature block.
The parent or guardian completes a Preparer and/or Translator Certification block on Supplement A.
The employer enters “Individual under age 18” under List B in Section 2.
The teenager presents a List C document only.

The regulation text itself uses the older wording “minor under age 18.” The current USCIS handbook uses “Individual under age 18.” I would follow the handbook, since it describes the current version of the form, and let the employer’s HR contact confirm if they use different software prompts.

Because the parent or guardian completes and certifies Section 1, plan for them to take part when the paperwork is done.

The E-Verify exception

I would check this rule first. The handbook says that if the employer participates in E-Verify, a parent or guardian cannot establish identity for a minor. The teenager must present either a List A document, or a List B document that contains a photograph plus a List C document.

At an E-Verify employer, a report card does not satisfy List B. It has no photograph. Ask the employer whether they use E-Verify before the first day, and if they do, a school photo ID or a state ID card becomes the practical route.

Work authorization (List C)

Two List C documents on the USCIS list apply to a US-born teenager.

An unrestricted Social Security card. The USCIS acceptable documents page says the card must not be laminated, and cards carrying “NOT VALID FOR EMPLOYMENT,” “VALID FOR WORK ONLY WITH INS AUTHORIZATION” or “VALID FOR WORK ONLY WITH DHS AUTHORIZATION” are not acceptable.

A birth certificate. It must be an original or certified copy issued by a state, county, municipal authority or US territory and bear an official seal. USCIS adds that a Puerto Rico birth certificate is acceptable only if issued on or after July 1, 2010.

Other List C options exist, including State Department reports of birth abroad (Forms FS-545, DS-1350 and FS-240) and certain DHS-issued documents. The acceptable documents page lists them in full.

If the Social Security card is lost, the Social Security Administration replaces it for free. SSA says the card arrives by mail 5 to 10 business days after the request is completed. Under 8 CFR 274a.2, a receipt for a replacement of a lost, stolen or damaged document can be used in the meantime, provided the replacement is shown within 90 days of the hire. That receipt option does not apply to a job lasting less than three business days.

The deadline

The employer must examine the documents and complete Section 2 within three business days of the first day of work, per the USCIS handbook. Its own example: an employee who starts on Monday must have documents reviewed by Thursday. For a job shorter than three business days, it has to happen on the first day. The handbook also says an employer may terminate an employee who does not present acceptable documents or an acceptable receipt within three business days.

What to gather before the first shift

Ask the employer whether they use E-Verify.
Find one identity document: a school photo ID, a state ID or license, or, if the employer does not use E-Verify and there is no photo ID, a report card or school record.
Find one work authorization document: the original, unlaminated Social Security card or an original or certified birth certificate with an official seal.
If neither a List B document nor an under-18 substitute exists and the employer does not use E-Verify, plan to be there to complete Section 1 and Supplement A yourself.

The wider list of things to sort out before day one is in the first job checklist.

Common questions

Can the employer insist on a driver's license?

No. The USCIS employer handbook says the employer must let the employee choose which documents to present from the Lists of Acceptable Documents and cannot specify which ones. A teenager can offer a List A document on its own, or one List B plus one List C document.

Will a photocopy of the birth certificate work?

Not a plain photocopy. The handbook says copies are not acceptable when documents are physically examined, with one exception: a certified copy of a birth certificate. The certificate must be issued by a state, county, municipal authority or US territory and bear an official seal.

The Social Security card is laminated. Is that a problem?

It can be. The USCIS acceptable documents page says the card must not be laminated to count as a List C document. Cards marked “NOT VALID FOR EMPLOYMENT” or valid only with INS or DHS authorization are also not acceptable for List C.

How long does my teenager have to bring the documents?

The employer must examine the documents and complete Section 2 within three business days of the first day of work, or on the first day if the job lasts less than three business days. The handbook says an employer may terminate an employee who does not present acceptable documents, or an acceptable receipt, within three business days.

What if the card was lost and the replacement has not arrived?

Under 8 CFR 274a.2, a receipt showing an application to replace a lost, stolen or damaged document can stand in temporarily. The replacement itself must be shown within 90 days of the hire. A receipt is not accepted for a job lasting less than three business days.