Certified Translation for Employers and I-9 Checks

What HR can and cannot ask for during Form I-9 verification, and which foreign-language documents actually need a certified translation on file.

An HR coordinator opens a new hire packet and finds a birth certificate in Spanish, a university diploma in Arabic, or a driver's license from Ukraine. The instinct is to ask for an English version before anything goes in the file. That instinct is reasonable, but it collides with a rule that catches employers off guard: for Form I-9 purposes, asking for a specific document — or for more documents than the form requires — can itself be a violation. The translation question and the I-9 question are separate, and conflating them is where companies get into trouble.

This guide separates them. What the I-9 actually asks for, where foreign-language documents genuinely do need an English version, and how to set a policy that treats every candidate the same way.

What Form I-9 actually asks for

Form I-9 verifies identity and work authorization. The employee chooses which document or combination of documents to present from the Lists of Acceptable Documents published by USCIS. The employer examines the document, decides whether it reasonably appears genuine and relates to the person, and records the details.

Here is the part that surprises people: almost every document on the I-9 lists is already in English. A US passport, a Permanent Resident Card, an Employment Authorization Document, a state driver's license, a Social Security card, a US birth certificate — all issued in English by US authorities or by the federal government. A foreign passport appears on List A only in specific combinations, such as a foreign passport containing a Form I-551 stamp or temporary I-551 printed notation, or a foreign passport presented with a Form I-94 for certain nonimmigrant categories. In those cases the relevant endorsement is in English.

The I-9 lists were built so that an HR generalist can verify work authorization without reading a second language. If you find yourself needing a translation to complete an I-9, you are probably looking at a document that does not belong on the form.

That is the practical test. A document that requires translation to be understood is usually not an acceptable I-9 document in the first place, and the answer is to let the employee present something from the lists — not to translate what they handed you.

The line you cannot cross: document abuse

The anti-discrimination provision of the Immigration and Nationality Act prohibits what is commonly called document abuse. In plain terms, an employer may not:

Demand a specific document, such as insisting on a Permanent Resident Card when the employee offers a driver's license plus a Social Security card
Request more or different documents than the I-9 requires
Reject documents that reasonably appear genuine and relate to the person
Treat employees differently during verification based on citizenship status or national origin

Asking a foreign-born employee for a translated birth certificate while asking nobody else for one sits squarely inside that list. So does asking for "proof of status" because an employee has an accent or a foreign name. The employee selects; you verify what is presented.

None of this prohibits translation. It prohibits selective and excessive demands. If an employee voluntarily presents a document you cannot read, you are allowed to ask for clarification — but the safer path is to point them back to the Lists of Acceptable Documents and let them choose again.

Where a certified translation genuinely belongs in a hiring file

Outside the I-9, there are real situations where an employer needs an English version of a foreign-language document, and no anti-discrimination rule stands in the way as long as the requirement applies to everyone in the same role.

Educational credentials. A job that requires a bachelor's degree requires it from every applicant. If a candidate's diploma or transcript is in Portuguese, an English version is how the requirement gets verified. Our guide on translating a diploma for a US employer covers what the English version should show, and the diploma and transcript translation page covers both documents together.
Professional licenses and certifications. Nursing, engineering, accounting, commercial driving. Licensing boards usually have their own translation standards, and the employer file often mirrors what the board accepted.
Driving records for fleet roles. If an insurer or a state program requires a review of driving history, a driver's license translation or an abstract of the foreign driving record may be part of the file.
Background check inputs. A foreign police certificate used in a regulated industry needs an English version before anyone can act on it.
Immigration sponsorship. If the company is petitioning for an employee, the filing itself is governed by immigration rules, not HR practice, and the translation standard is federal.
Name discrepancies. When a payroll name does not match a Social Security record because of a name change abroad, a translated marriage certificate or court order can document the change.

The rule of thumb: translate what the job requires, not what the person's nationality suggests.

What the certification has to say

When a translation goes into a personnel file, the thing that gives it weight is the attached certification. The federal standard that most US institutions borrow from is 8 CFR 103.2(b)(3), the rule governing documents filed with USCIS. It requires a full English translation of the foreign-language document plus the translator's certification that the translation is complete and accurate and that the translator is competent to translate from that language into English.

That is the whole rule. It does not require a credentialed or government-licensed translator, and it does not require notarization. Employers who insist on a notary are usually importing a habit from real estate closings: a notary public verifies the identity of the signer, not the accuracy of a translation, and in most US states a notary is actually barred from attesting to accuracy.

A usable certification names the translator, states the language pair, identifies the document, affirms completeness and accuracy, affirms competence, and carries a signature and date. A Certificate of Translation Accuracy that does those six things is what an auditor, an insurer or opposing counsel will look for three years from now.

For the practical difference between a certificate and a notary stamp, the comparison in certified vs. notarized translation is worth ten minutes of an HR team's time before you write a policy that requires something nobody needs.

Who should not be translating it

The most common shortcut in a hiring file is also the weakest: a bilingual colleague translates the document over lunch, initials it, and it goes in the folder.

The problem is not language skill. It is impartiality and documentation. A coworker's informal translation has no certification attached, no named translator of record, and an obvious interest in the hire going smoothly. If the file is ever reviewed — in an audit, a wage dispute, a licensing inquiry, a wrongful termination claim — there is nothing to point to that establishes the English text is complete.

The same applies to the employee translating their own documents, and to machine output. Machine translation of a diploma will usually render the degree name as something that does not exist in the US system and will silently skip stamps, seals and handwritten endorsements. Our note on using Google Translate for official documents walks through exactly where that breaks.

An independent translator with a signed certificate solves all of this for less than the cost of an hour of the colleague's time. Translations prepared for employers are built around that documentation need.

Writing a policy that survives an audit

The goal is a rule you apply identically to every candidate, written down before anyone needs it.

Separate your I-9 process from everything else. Different form, different folder, different instructions to the hiring manager. Nothing about credentials or translations belongs in the I-9 workflow.
Define the translation trigger by role, not by person. "Positions requiring a bachelor's degree require degree documentation in English" applies to the graduate of a state school and the graduate of a university in Seoul alike.
State who pays. There is no federal rule here. Many employers cover translation when the document is verified for the company's benefit. Decide once, write it down, apply it consistently.
Specify what you accept. A complete English translation with a signed certification of completeness, accuracy and competence. Name the standard; do not invent extra requirements like notarization or apostilles. An apostille certifies an underlying public document for use abroad under the Hague Convention and is issued by a government authority — it has nothing to do with a translation and does not belong in a hiring policy.
Keep the original alongside the English. A translation without the source document is hard to audit. A legible scan or photo of both is normally sufficient; originals rarely need to be mailed anywhere.
Set a turnaround expectation. Most one- to three-page documents come back within 24 hours, so a translation requirement does not have to delay a start date.

What it costs to do this properly

Budget is usually the reason a policy gets written loosely. The numbers are smaller than most HR teams assume.

Certified translation runs $24.95 per page, where a page means up to 250 words including numbers — not a physical sheet. A diploma is typically one page. A two-year transcript might be two or three. A foreign driver's license is one. The full pricing breakdown shows what is included: the signed Certificate of Translation Accuracy, formatting that mirrors the original so a reviewer can compare line by line, digital PDF delivery, and revisions.

Standard translation is the same $24.95 per page. It is not a cheaper tier. The only difference is that a standard translation comes without the Certificate of Translation Accuracy — appropriate for an internal reference document nobody will ever have to defend, and wrong for anything going into a personnel file. For a hiring file, order certified; the certificate is the entire point.

Notarization, physical mail and same-day delivery are optional add-ons priced at checkout. For a straightforward employer file, you will rarely need any of the three. If you want a figure before committing, a quote takes a document upload and returns a page count.

Frequently asked questions

Does Form I-9 require a certified translation of a foreign document?

Form I-9 itself does not require a translation. The List A, B and C documents that satisfy I-9 are US-issued or standardized documents like a US passport, a Permanent Resident Card or an Employment Authorization Document, all of which are already in English. A translation question only arises for documents outside the I-9 lists, such as a foreign diploma used for a role requirement.

Can an employer require a new hire to provide a translated birth certificate?

An employer cannot demand specific documents for I-9 purposes; the employee chooses which acceptable document to present. Requiring a particular document from a foreign-born worker but not from others is document abuse under the anti-discrimination provision of the Immigration and Nationality Act. Requests for translated credentials outside I-9 should be applied to every candidate equally.

Who should pay for a certified translation of an employee's documents?

There is no federal rule assigning the cost. Many employers pay when the translation is for the company's benefit, such as verifying a foreign degree, and leave the cost with the applicant when the document is part of a personal immigration filing. Setting the policy in writing before you ask is the cleanest approach.

Does a translation for an employer have to be notarized?

Notarization is almost never required. A notary verifies the identity of the signer, not the accuracy of a translation, and in most US states a notary is barred from certifying accuracy. A signed Certificate of Translation Accuracy from the translator is what gives the document its standing in a personnel file.