Assemble the joiner file, hold section 2 of the Form I-9 for the named representative who examines the documents and signs the attestation, and carry the leaver deadlines that run on money.
A joiner starts, and the section 2 clock runs from hire — 8 CFR 274a.2(b)(1)(ii)(B).
02
A document is presented, and what arrived is recorded without a view on whether it is genuine.
Reason
03
A list is offered, and which document to show stays the choice of the person presenting it.
04
An extra document is asked for, and 8 U.S.C. 1324b(a)(6) is read before the ask goes out.
05
A remote look is proposed, and E-Verify standing is checked against 88 FR 47749 first.
Decide
06
A mismatch is contested, and revocation and pay holds are held back until the case closes.
07
A leaver is coded, and discharge or resignation goes back to a human before final pay.
Out
08
A file ages, and retention runs on 8 CFR 274a.2(b)(2)(i)(A), which the leaving date sets.
09
Execute provisioning and revocation only inside the approval boundaries agreed at implementation.
→Product statement
Assembly, sequencing and retention belong to the agent. The examination and the signature belong to a named representative, and filling the form for a signer who did not look moves the exposure onto that signer rather than dividing it.
Example workflow
One joiner, offer to attestation
AgentHuman
1Offer accepted and hire date setStart date, work location, legal entity and the state whose separation rules will apply
2Joiner file opened and clockedThe three-business-day section 2 deadline, counted from the hire date on the payroll record
3Documents received and loggedWhat the joiner chose to present, the day it arrived, and the copies retained against it
4Checks appliedDocument-request checks, list-neutrality checks, E-Verify standing and deadline proximity
No human action required
Stages 1 to 4 run unaided, and nothing is attested at any of them — 8 CFR 274a.2(a)(3) puts that signature under penalty of perjury, and the representative lane opens at the examination gate.
5DecisionSplits at the examination gate
Standard joiner
Goes to the named representative to examine.
Anything contested
Adds an immigration-counsel read first.
Representative review
The file is held with the documents presented, the deadline left, and the checks that ran.
Attest · Request correction · Send to counsel review
Attested — by the named representative▼
6Directory, payroll and records updatedOnly where write access and the records policy allow it
7Outcome measuredDeadline adherence, request neutrality, corrections and what review found
Corrections
Each representative correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Signing the section 2 attestation.
Examining a document a joiner presents.
Judging that a document appears genuine.
Recording a leaver as discharged or resigned.
Automation boundaryAgent acts unaided
✓Count the three business days from the hire date.
✓Hold the joiner file unattested until a named representative looks.
✓Carry each separation deadline through to the payroll administrator.
✓Check E-Verify standing before any remote look.
Nothing is attested except by a named representative who looked, inside the boundaries.
Deciding whether a mismatch may end employment.
Refusing a document a joiner has offered.
Judging wilfulness under Cal. Lab. Code section 203.
Changes to the checklist, the entity or the clock.
Example output
One joiner record, annotated
This serves a people-operations team whose files may be read by an inspector years after the person joined; below is one joiner record exactly as the agent leaves it, unattested.
Joiner record · section 2 pendingIllustrative example
Stage
Recorded as
Deadline
Evidence held
Confidence
Held for
New joiner, documents presented
Documents logged, not examined
Section 2 open
List B and List C, 3 August 2026
Held unattested
The named representative, by name
As receivedAssembled from what the joiner chose to present, and it claims nothing about whether it is genuine.
What this record holdsDocuments presentedDeadline leftCopies retained
Why no attestation hereAttesting under penalty of perjury is something a named person does.
ActionAttestRequest correctionSend to counsel review
What the score decidesNo 2026 adjustment exists; the range at 28 CFR 85.5 still runs from 3 July 2025.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every joiner fileFrom the offer that opened it
03Evidence
Where that evidence is used
No Form I-9 edition date is printed here: uscis.gov could not be read on the day of writing, and only the OMB approval at 1615-0047, expiring 31 May 2027, was confirmed.
01Approved path
Somebody has to look
8 CFR 274a.2(b)(1)(ix) dropped the same room and the physical handling, and kept a live video interaction with the individual presenting the documents. It stopped at the person.
02Human review
Searched for, and not there
Of the three regimes usually invoked to make revocation sound urgent, 45 CFR 164.308(a)(3)(ii)(C) is addressable and carries no deadline, 15 U.S.C. 7262 says nothing about it, and PCI DSS is contractual. The hard leaver clocks are money.
04Build an evidence trail
The step, the evidence it required and the representative who attested it stay together.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
HR and payroll systemsHRIS · payroll · time records Hire dates and separation events
Verification recordsForm I-9 store · E-Verify Attestation status and copies
Directory and access systemsIdentity provider · device records Accounts opened and later revoked
Agent
Joining and leaving checklists
Assembles the file Runs the deadline clocks Holds for the representative
Separation and final payTermination notices · benefit plans Discharge or resignation coding
Integration availability depends on the client's existing systems and API access.
Agent controls
Six catches between the file and the signature
Six catches upon one latch, the last the surest. What releases is drawn in the map below.
L6 · Outermost — last line of defenceInward → L1 · closest to the model
L6Rollback / safe modeNarrow the agent to document logging when evaluation or production signals degrade.Roll back
L5Version watchTrack model, prompt and checklist rules, and note the version each joiner file was run under.Track
L4TraceabilityRecord each step, the documents logged under it, the deadline it ran to and every read of the file.Record
L3Attestor releaseHold the file for a named representative; the hold governs release, not whether anyone examined the documents.Gate
L2Request guardrailsTest each document request against the lists a joiner may choose from, and refuse one asking for more or different documents.Restrict
L1Deadline thresholdsRoute a file inside one business day of a section 2 deadline, or of a Cal. Lab. Code 201 or 202 final-pay date, to a second reviewer.Require review
Model coreFile assembled — the documents logged, the copies held, the deadline and the checks
L1 – L2Test whether a file may go forward
L3Leaves the attestation to a named representative
L4 – L5Keep the step and the attestation behind it
L6Halts the checklist at the attestation when signals degrade
How Nestack evaluates it
Evaluate the whole joiner run — not only the file that comes out.
Coverage runs the whole depth of the workflow, and every layer is cut by slice.
Surface — the file an inspector would read
Depth of coverage ▼
E1Final-output evaluationDid the file record which documents were actually presented?
E2Step-level evaluationDid the agent read the right hire date, the right entity and the live checklist?
E3Tool evaluationDid it write to the correct joiner and the correct record?
E4Confidence calibrationDo low-confidence files actually attract more representative corrections?
E5Slice evaluationHow does performance change across specific joiner classes?
E6Business outcomeHow many files needed a correction before the representative attested?
Floor — the checklist a file is run against
Failure modes
Where each failure originates in the agent
Seven failure modes, each shown where it first becomes visible in the run.
Agent lifecycleDirection of processing →
01 · Retrieval1 mode
UA-03
Superseded form template read
The stored template is not the one now published.
Stage gathersThe hire date, the documents and the copies
02 · Reasoning2 modes
UA-04
Extra documents requested
A safer setting asks for more than the law allows.
UA-06
Genuineness assumed, not examined
A file reads as verified with nobody having looked.
Stage proposesThe document list, the deadline and the checks
03 · Tool / write2 modes
UA-02
Remote look without standing
The alternative runs where E-Verify standing lapsed.
UA-05
Revocation on a contested mismatch
Access and pay stop while the case is still open.
Stage writesOnly where write access and approval policy allow it
04 · Output1 mode
UA-01
Attested, examination unrecorded
The record shows a signature but not the looking.
Stage returnsThe file a named signer reads before signing
05 · Change / Version1 mode
UA-07
Silent deadline drift
A rule moves and the stored clock keeps the old one.
Stage tracksModel, prompt, checklist rules and form dates
Sev-1 · a signature on an unseen documentSev-2 · a leaver deadline missed by a daySev-3 · standing lapses, file held back
No published error rate exists for commercial electronic I-9 systems, so a site figure can read clean while remote-examination joiners carry the corrections. Nestack reports by joiner class.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Remote-examination joiners
12.0%
3.7×
Review
Multi-state separations
8.5%
2.6×
Review
Contested-mismatch cases
5.3%
1.6×
Watch
Standard in-person joiners
2.4%
0.7×
Normal
Bar: correction-rate lift vs. in-person joiner baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
What a late final payment costs
A loop closes when the form completed by nobody in particular is a standing case. That suite is what the next joiner run is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Correction rate rises on remote-examination joiners.
02Diagnose
The leaver whose accounts shut within the hour while final pay ran past Cal. Lab. Code 201 is worked backwards until one cause is left standing.
03Improve
The checklist goes out numbered, and the evidence beneath it rides with it.
04Verify
One attestation case still failing is enough to hold the start back.
05Learn
It is kept for good, and the checklist rules are amended in the same commit.
Learn → DetectThe return edge. The next joiner run is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, systems, checklist build, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Attestation-boundary and joiner-checklist definition.
02Verification, payroll and directory data.
03Step-to-attestation and deadline-coverage reporting.
04Joiner document intake.
05Hire date, entity and clock binding.
06Deadline scoring and review routing.
07Representative attestation workflow.
08Directory and payroll integration.
09Attestation and deadline cases.
10Guardrails and provisioning controls.
11Step-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne entity, one joiner cycleProductionProduction joining workflowAdvancedMultiple entities / states
Introduced at Pilot
Checklist run to your steps✓✓✓
Named representative attestation✓✓✓
Joiner-and-leaver baseline✓✓✓
Introduced at Production
Reporting by step class—✓✓
Representative review workflow in your systems—✓✓
Approved provisioning write-back—✓✓
Directory-and-payroll integration—✓✓
Introduced at Advanced
Multi-state separation rules——✓
Cross-entity joiner packs——✓
Large joiner and leaver volumes——✓
Multi-state final-pay controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, joiner volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your live joining and leaving checklists→Checklist capture and attestation-boundary definitionWeek 1
02Representative HRIS, payroll and directory access→System binding, step logic and the joiner baselineWeek 2
03Your legal entities and the representatives they name→Checklist mapping, step binding and the automation boundaryWeek 1
04Access to relevant APIs, feeds or exports→HRIS, payroll and directory assessment, then integration setupWeek 2
05Records you would not want inspected→Attestation cases and the failure roundWeek 4
06What no checklist may certify→Deadline scoring, review routing, guardrails and release controlsWeek 3
07A named representative who attests→Release to the named representative, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
Two of these phases genuinely share week five, and no band was stretched to make the column tidier.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Checklist discovery, attestation boundary and the automation boundaryW2System integration and the joiner-and-leaver baselineW3Step logic, deadline clocks and release controlsW4Evaluation suite, attestation cases and the failure roundW5Directory and payroll integration, pilot joiners and targeted correctionsW6One joiner cycle run under the people-operations lead, then Agent Care handover
Reading the bandEach band spans only the weeks its own work is named for, and week five is shared by design.
At the end of W6Once the attestation record validates, Agent Care takes the agent up.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · HR AI agent
Build a joining and leaving agent around the examination your last attestation assumed.
Show us one joiner file and the signature on its section 2. If the signer cannot say which documents were examined, the signature carries work the examination never did. An AI tool has already produced the citizenship-status version of that failure: DOJ, 25 February 2026.
