On October 8, 2026, the Department of Homeland Security (DHS) published a proposed rule creating new fees for schools that recommend F-1 students for Optional Practical Training (OPT). This proposed rule must go through a public comment period and be finalized with a future effective date. Current OPT and STEM OPT rules and fees remain in effect, and OISS continues to process OPT recommendations as usual.
Summary of proposed changes
- A $70,000 fee for each F-1 student's first OPT recommendation, whether pre-completion or post-completion OPT.
- A $30,000 fee for each subsequent OPT recommendation, including the STEM OPT extension.
- The fee would apply to recommendations for any type of OPT. OISS (on behalf of the university) would have to pay it before we can issue an I-20 with an OPT recommendation. DHS notes that schools could pass these costs on to “F-1 nonimmigrant students, all students, or employers.”
- Curricular Practical Training (CPT) is not affected by this proposal, but prior to this proposed rule in August, DHS issued guidance limiting eligibility for CPT.
Timeline and impact
If finalized, the fees will apply only to OPT recommendations issued on or after the final rule's effective date. Under the proposal, that date is 60 days after a final rule is published. Students currently on OPT or STEM OPT, and students whose OPT is recommended or approved before the effective date, will not be charged for that OPT period. Any request made after the effective date, such as a STEM extension, will be subject to the fee.
We do not know if or when a final rule will be published, or whether it will change from the proposal based on any public comments that DHS is required to consider before adopting a final rule.
What should F-1 students do now?
- Don't make abrupt decisions about your studies, travel, or job plans.
- If you plan to apply for OPT or STEM OPT in the coming months, talk with your OISS adviser about your timeline and your individual situation.
- Applications for OPT can be submitted as early as 90 days before your program end date (post-completion OPT) or end of your current OPT period (STEM OPT).
- Post-completion OPT: You can learn more about the post-completion OPT application timeline here. For most Yale students, the program end date is the Commencement date (May 24, 2026, this year), but please check your I-20 for your actual program end date. If your program end date is the Commencement date in May, the earliest you can apply for post-completion OPT this year will be February 24, 2027 (90 days before your program end date).
- STEM OPT: You can learn more about the STEM OPT timeline here. Check the end date of your current OPT period; you can submit your STEM OPT extension application to USCIS as early as 90 days prior to that date.
- Keep an eye on your email and on our website. We will send you emails and post announcements with updates as we learn more.
Public comment period
DHS is accepting public comments on the proposal through November 9, 2026. Comments must be submitted at regulations.gov under Docket No. ICEB-2026-0100. All comments, including names and any personal details, are made public.
Yale is reviewing the proposal and will work with peer institutions and associations to preserve students’ access to OPT.
Questions?
Please contact your designated OISS adviser with any questions.