OPT fees could become one of the largest new financial obligations in the F-1 student immigration system if the Department of Homeland Security adopts a proposal published October 8, 2026.
U.S. Immigration and Customs Enforcement is proposing a $70,000 fee for an F-1 student’s first recommendation for Optional Practical Training and a $30,000 fee for each later OPT recommendation.
These proposed OPT fees would apply to recommendations made by SEVP-certified schools.
The proposed charges would be paid by Student and Exchange Visitor Program-certified educational institutions rather than directly by students or employers.
However, the size of the proposed OPT fees could influence whether schools recommend students for work authorization and could affect how institutions budget for international student programs.
Table of Contents
What DHS is proposing
The proposal would add a new fee system to the regulations governing practical training for F-1 nonimmigrant students.
An SEVP-certified school would pay $70,000 before its designated school official recommends a student for OPT for the first time.
That initial payment would be one of the proposed OPT fees assessed under the new system.
The initial fee would apply whether the student seeks pre-completion OPT during the academic program or post-completion OPT after finishing the program.
A school would pay another $30,000 before making a later OPT recommendation for the same student if the initial $70,000 fee had already been paid.
The subsequent charge would apply to later pre-completion OPT, post-completion OPT or a 24-month STEM OPT extension.
The fee would be tied to the school’s recommendation of the student, not to a particular employer.
A change in employers alone would not trigger another OPT fee under the proposal, although the proposed OPT fees could apply to a later recommendation covered by the rule.
How the fees would affect different types of OPT
OPT generally allows eligible F-1 students to obtain practical training directly related to their major or course of study.
Students may seek up to 12 months of OPT at an education level, although pre-completion OPT reduces the amount available after graduation.
Eligible graduates in qualifying science, technology, engineering and mathematics fields may seek a separate 24-month STEM OPT extension if they meet additional requirements.
Under the proposed structure, a student who begins with post-completion OPT would generally be associated with the $70,000 initial fee.
If the student later qualifies for STEM OPT, the school would generally face the $30,000 subsequent fee as part of the proposed OPT fees.
A student who uses pre-completion OPT and later seeks post-completion OPT could trigger both charges, producing a total of $100,000 for the two recommendations.
DHS says that difference could encourage schools and students to avoid splitting OPT between pre-completion and post-completion periods when a post-completion arrangement is practical.
The rule would not change the separate Form I-765 filing process through U.S. Citizenship and Immigration Services.
Students would still need a DSO recommendation, an endorsed Form I-20 and USCIS employment authorization before beginning work.
Who would pay the proposed OPT fees
The proposed OPT fees would be assessed against SEVP-certified educational institutions.
The school would have to make the payment before the DSO entered the recommendation in the Student and Exchange Visitor Information System.
USCIS would not grant employment authorization before the applicable fee was paid under the proposed regulatory language.
The proposal does not require the student’s employer to pay the charge.
It also does not expressly require a school to pass the cost directly to a student.
Even so, schools could respond through changes to tuition, international student services, scholarship policies, administrative charges or the number of OPT recommendations they approve.
Those decisions could determine how the proposed OPT fees affect students in practice.
The financial effect would therefore vary by institution and by the way each school chooses to administer its OPT program.
Why DHS says it wants the new charges
DHS says the proposed OPT fees are intended to combat fraud and abuse, encourage more careful institutional review and protect U.S. workers.
The agency argues that schools and designated officials are important gatekeepers because the initial OPT process does not require a student to have secured a training opportunity before seeking authorization.
DHS also discusses concerns about employer practices, oversight and the possibility that OPT can create incentives that affect hiring decisions.
The proposal would use the fee requirement to encourage schools to examine whether OPT recommendations are legitimate and connected to a student’s academic program.
Those statements are the agency’s rationale for the proposed rule and are not a final finding that every school, student or employer participating in OPT has violated immigration requirements.
Potential financial impact of proposed OPT fees
DHS estimates that the proposal could generate billions of dollars in annual fee transfers from educational institutions to the federal government.
The agency’s primary estimate is approximately $12.4 billion per year, with modeled estimates ranging from about $8.4 billion to $16.5 billion depending on participation.
Those figures reflect the proposed OPT fees rather than charges currently in effect.
DHS also acknowledges that some institutions may decide not to recommend OPT for certain students because the proposed charges could exceed the expected value of the training opportunity.
The agency’s analysis considers the possibility that schools would prioritize students eligible for the 24-month STEM OPT extension because the potential training period is longer.
That approach could reduce access to OPT for students in non-STEM fields or for students whose programs provide only the standard 12-month period.
The proposal could also affect smaller institutions with limited operating revenue and fewer international students over whom to spread the cost.
DHS estimates that some small affected institutions could face fee costs representing more than 20 percent of estimated annual revenue during the transition year.
Those estimates are projections contained in the proposed rule and could change if DHS revises the proposal after reviewing public comments.
When the proposed OPT fees would apply
The proposal is not a final rule and does not immediately impose the new charges or proposed OPT fees.
DHS proposes that a final rule would take effect 60 days after its publication in the Federal Register.
The proposed fees would apply to students whose DSO recommendation is dated on or after the final rule’s effective date.
Students already participating in previously approved OPT would not be subject to the new fee solely because the rule becomes effective.
The proposal also says schools would not have to pay for a student who had already received a DSO recommendation before the effective date.
A later request for another period of OPT after the effective date could trigger the applicable fee.
The November 9, 2026, date is the deadline for comments on the proposed rule, not the date on which the proposed charges automatically begin.
Comments concerning the information collection described under the Paperwork Reduction Act have a separate December 7, 2026, deadline.
How to submit a comment
Interested members of the public may submit comments through Regulations.gov using DHS Docket No. ICEB-2026-0100.
Comments should identify the specific part of the proposal being addressed and explain the reasoning or supporting data for any recommended change.
Comments must be submitted in English or accompanied by an English translation.
DHS says comments submitted by email or ordinary mail will not be treated as comments on the rule unless the agency provides alternate instructions for a person who cannot use the online portal.
Because comments may be posted publicly, individuals and organizations should avoid including unnecessary personal information in their submissions.
What F-1 students and schools should do now
F-1 students should continue following the OPT process currently in effect unless and until a final rule changes the requirements.
Students considering OPT should speak with their DSO about eligibility, timing, the required Form I-20 and the Form I-765 filing process.
Students should not begin employment until they have the required employment authorization and the authorization period has started.
Schools should review the proposal’s fee structure, identify students who may be affected and evaluate how the proposed OPT fees could affect international student services and institutional budgets.
Employers that rely on F-1 student workers should monitor the rulemaking because school decisions about OPT recommendations could affect future hiring and training plans.
No student should assume that the proposal has already changed current OPT eligibility or that a $70,000 payment is currently required.
What happens next
DHS will accept comments through November 9, 2026, and may revise, withdraw or finalize the proposal after reviewing the record.
If DHS issues a final rule, the final text will determine the exact fees, effective date, transition rules and any changes from the October 8 proposal.
Until then, the proposed OPT fees remain under consideration and are not a current charge imposed on F-1 students or SEVP-certified schools.
Frequently Asked Questions
Are the proposed OPT fees currently in effect?
No. The October 8, 2026, publication is a proposed rule. The $70,000 and $30,000 charges would not apply unless DHS issues a final rule that adopts them.
Who would pay the proposed OPT fees?
The proposed fees would be paid by SEVP-certified educational institutions before a designated school official recommends the student for OPT.
How much would the initial OPT fee be?
The proposal would establish a $70,000 fee for a student’s first OPT recommendation, whether the recommendation is for pre-completion or post-completion OPT.
When would the $30,000 subsequent fee apply?
The $30,000 fee would apply to a later OPT recommendation after the student had previously participated in OPT and the initial $70,000 fee had been paid. The proposal includes later STEM OPT recommendations.
When are comments due?
Comments on the proposed rule must be received by November 9, 2026. Comments on the information collection have a separate December 7, 2026, deadline.
Would the proposed fees be charged when a student changes employers?
No. Under the proposal, the charge would be tied to a school’s OPT recommendation rather than simply to a change in employer.
Fact-Checked: Verified against the Federal Register proposed rule published October 8, 2026, and current ICE practical-training guidance. The fee amounts and deadlines remain proposals, not final requirements.
Disclaimer: This article is for general information and does not replace advice from a designated school official or qualified immigration attorney.
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