Despite the deal appearing along with other completed contracts in NFLPA records, a Bills spokesperson said Wednesday there has been no deal signed between the two sides. Holmes also tweeted Wednesday afternoon that he had not signed with any team.
An NFLPA spokesperson did not immediately respond to a request for comment from ESPN.
Holmes' deal would include $2.425 million in guaranteed money, documents showed. Holmes would be paid salaries of $925,000 in 2017, $950,000 in 2018 and $975,000 in 2019.
He will receive a $1.5 million signing bonus and workout bonuses of $50,000 each season. His 2017 salary is fully guaranteed. He can earn up to $750,000 in incentives each season and has base salary escalators based on playing time.
Holmes, 28, played the role of a third or fourth receiver, along with Seth Roberts, behind Amari Cooper and Michael Crabtree last season for the Raiders. But he also is a big target in the red zone at 6 feet 4, 210 pounds, and he made a name for himself as a special teams ace alongside Taiwan Jones.
Holmes had nine special teams tackles, which ranked third on the team, and recovered a fumble on a muffed punt at Jacksonville in Week 7. He also led the Raiders with 50 receiving yards on four catches, including a touchdown, in Oakland's playoff loss at Houston.
His production has faded as the Raiders have improved, going from 47 catches for 693 yards and four touchdowns for a 3-13 team in 2014 to 14 catches for 201 yards and three touchdowns for a 7-9 team in 2015 to 14 catches for 126 yards and three touchdowns for a 12-4 playoff team last season.
Holmes, who had a base salary of $2 million in 2016, originally entered the NFL as an undrafted free agent out of Hillsdale College with the Vikings in 2011.
ESPN's Paul Gutierrez contributed to this report.