When a candidate disputes something on their background check, your screening company has to reinvestigate it. Not you. Them. That's the rule under FCRA Section 611, and it's the part of this process most employers never hear about until it happens to them.
I spent over a decade on the operations side of a background screening company, and dispute reinvestigations came across my desk regularly. Most employers freeze up the first time. Let's walk through what's actually supposed to happen, and what your job is while it's happening.
This trips people up because it feels backwards. The candidate is disputing a report you're using to make a hiring decision, so it seems like your problem to solve. It isn't. Not directly.
Under the FCRA, the consumer reporting agency, your background check company, is the one legally required to reinvestigate. The candidate contacts them, not you, and lays out what they think is wrong. Your provider then has to go check it.
That's not a courtesy your vendor is extending. It's their legal duty under federal law. If they blow it off or drag their feet without reason, that's on them, not on you. Good to know if you're ever wondering whether you're the one who's supposed to be digging through county court records right now. You're not.
The FCRA generally gives a CRA a reasonable period of time to reinvestigate, and that's commonly cited as around 30 days from when they get the dispute, sometimes with about 15 more tacked on if the candidate is still sending in extra information.
I'm hedging that number on purpose. The exact rules around what counts, what pauses the clock, and how it applies in your specific case can shift, and I've seen employers get burned trusting a summary, mine included, over their provider's own compliance team.
So to say that a different way: expect somewhere around a month, plan for it to sometimes run a little longer, and verify the current rule with your vendor or a lawyer instead of treating any one article as gospel.
If a dispute is dragging well past that with no update, that's worth a phone call. If it wraps up in two weeks, that's normal too.
Mostly, nothing. That's not me being lazy about the answer. Waiting is genuinely the correct move here, and it's the part employers have the hardest time sitting with.
Your provider may come back and ask you for something, usually paperwork you already have on file. Think an offer letter, a job description, or dates confirming when someone actually worked for you, if the dispute involves employment history.
Give them what they ask for quickly. That's the extent of your active role most of the time.
What you shouldn't do is call the courthouse yourself, or the candidate's old employer, trying to sort it out faster on your own. That's your provider's job under the law, and freelancing it yourself can muddy a process that's supposed to stay documented and consistent. Let them run it.
Technically nothing stops you from making a decision mid-dispute. Practically, I'd tell you not to, and here's why.
If you reject a candidate based on the disputed item and it later comes back changed or removed, you made an adverse decision on information that turned out to be wrong. That's a real problem, not a technicality.
It can look a lot like you ignored the dispute process entirely, even if that wasn't your intent.
The safer move, and the one most employers I've worked with actually take, is to pause. Hold the position open if you can, or at least hold off on a final adverse action notice until the reinvestigation finishes.
A few extra days of waiting is a lot cheaper than defending a decision built on a report your own provider was actively correcting. Nothing on paper forces your hand here. Do it anyway.
Your provider sends back one of two outcomes. Either the disputed item gets corrected or removed, or it gets verified as accurate and stays on the report.
If it's corrected, you're now looking at a different report than the one you started with. Review the updated version before you decide anything, not the original.
If it's verified, you proceed the way you would have anyway, through the normal adverse action steps if you're still leaning toward not hiring.
Either way, the candidate has to be notified of the result directly by the CRA. That's not something you need to relay yourself, though it doesn't hurt to loop back with them once you've got your own decision made.
Disputes aren't common. Most reports never get one. But when it happens, it's usually because the candidate genuinely believes something on that report isn't them, or isn't right. Sometimes they're wrong. Sometimes the report is.
Either way, the reinvestigation exists so you're not the one deciding which, off a hunch, under time pressure.
Talk to your provider's compliance team, or a lawyer, if a dispute on a live candidate feels murky in the moment. This is a process detail, and the exact procedural rules can shift. It's not a substitute for someone checking your specific situation.