OPT Fee Proposal 2026: What the $70,000 and $30,000 Fees Would Mean

What happened on October 8, and who should read this?

The Department of Homeland Security published “Optional Practical Training Fees” as a notice of proposed rulemaking on October 8, 2026. This guide is for F-1 students preparing for graduation, students already working on post-completion OPT, and students planning a STEM OPT extension. It also helps families interpret headlines without turning a possible future cost into an immediate payment instruction.

A proposal starts a rulemaking process. It does not, by itself, change your current Employment Authorization Document (EAD), approve a new application, or create a payment requirement. The useful next step is to identify your next real immigration milestone: program completion, a DSO recommendation, an I-765 filing, or an EAD expiration.

Keep three dates separate when reading the news: the proposal’s publication date, its public-comment deadline, and any later final-rule effective date. Only the third would tell you when a finalized requirement starts. The final text could differ from the proposal, so a headline is not enough to plan a filing.

Sources: Optional Practical Training Fees: October 8 proposed rule, sections V–VI

1. 1. What happened: DHS published the proposal on October 8, 2026.
2. 2. What applies now: existing OPT rules and your actual filing deadlines.
3. 3. What comes next: comments, agency review, and a possible final rule.
4. 4. Only if finalized: check the final effective date and transition language.

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Who would pay the $70,000 OPT fee?

Under the proposed approach, the SEVP-certified educational institution would make the government payment before its designated school official (DSO) recommends OPT in SEVIS. The first fee is proposed at $70,000. Another OPT recommendation would be subject to $30,000 after the student’s initial fee has been paid under this system.

The first recommendation could be for pre-completion OPT, post-completion OPT, or a STEM OPT extension. “Initial” in this fee proposal should not be read as a guarantee that every first STEM extension costs only $30,000. The proposed transition matters for students who participated in OPT before this fee system existed.

The proposal identifies the school as the payer to the government. It does not tell you what your own school will ultimately offer or what the full financial arrangements would be if a rule becomes effective. Ask the university for its written position before making tuition, loan, enrollment, or job decisions based on a guessed cost.

Sources: Optional Practical Training Fees: October 8 proposed rule, sections V–VI; OPT fee proposal: original agency text and proposed transition provision

• Proposed payer: the SEVP-certified school.
• Proposed first fee: $70,000 before the DSO’s recommendation.
• Proposed later fee: $30,000 after a prior initial fee payment.
• Current action: verify legitimate USCIS filing instructions; do not pay a new fee from a social-media link.

Three fictional students: graduation, STEM OPT, and pre-completion OPT

These examples are fictional planning scenarios, not predictions, legal determinations, or stories about TrackMyOPT customers. They use the proposal as written to show which facts would matter if it were finalized without changes.

Priya is finishing a master’s degree in December 2026 and preparing her first post-completion OPT application. Today, she should obtain her DSO recommendation and follow the current filing window. If a future final rule takes effect before her recommendation, her school would need to evaluate the new requirement. She should not invent an effective date or miss a valid filing window while waiting for news.

Daniel already holds a post-completion OPT EAD and plans to seek STEM OPT in spring 2027. His school has never paid an initial fee under the proposed system. The transition provision would require $70,000 for a recommendation on or after the eventual effective date, including a STEM recommendation. His existing EAD does not mean that every future recommendation is automatically exempt.

Mei is considering pre-completion OPT now and post-completion OPT later. In a hypothetical future system where her school pays $70,000 for her first recommendation, the proposed subsequent fee could add $30,000 for the later recommendation. The combined $100,000 describes two school payments in that scenario, not an automatic invoice to Mei today.

For all three students, the practical task is the same: document the next recommendation and filing dates, ask the school what it can confirm, and keep current compliance obligations separate from conditional financial planning.

Sources: OPT fee proposal: original agency text and proposed transition provision

• Compare pre-completion OPT and CPT
• Prepare a STEM OPT extension

What would trigger a fee, and what would not?

The proposed trigger is the school’s OPT recommendation, rather than each job change. For example, Daniel moving between employers during an already-authorized OPT period would not, by that fact alone, cause this new proposed payment. He would still need to follow the employment-reporting rules that apply to his current authorization.

Do not combine this OPT proposal with the separate H-1B fee proposal. OPT recommendations and an employer’s H-1B petition are different processes, with different proposed payers and triggers. A recruiter discussing H-1B sponsorship cannot confirm what your university will do about an OPT recommendation.

Paying a fee would not replace eligibility requirements or guarantee employment authorization. A student would still need to satisfy the rules governing the requested training and application. Conversely, the news does not give a pending initial OPT applicant permission to start work early.

Sources: Optional Practical Training Fees: October 8 proposed rule, sections V–VI; Optional Practical Training for F-1 Students; Fee for Certain H-1B Petitions (proposed rule, 91 FR 54817)

• Understand the separate proposed H-1B fee
• Can you work before your OPT EAD arrives?

What could happen next? Read the transition carefully

The proposal would have a final rule take effect 60 days after publication of that final rule. That is a proposed transition period, not a countdown starting on October 8. There is no confirmed implementation day to calculate from the proposal alone.

Its transition language would apply the initial fee to a recommendation dated on or after the future effective date when an initial fee has not previously been paid. A prior OPT history by itself would not necessarily protect a later STEM recommendation. Ask about the date of the recommendation, the history of fee payment under the new system, and the final transition text.

Possible next steps include reviewing public comments, publishing different final provisions, or leaving the proposal unfinalized. Any later litigation would need to be assessed separately. These are possible process outcomes, not a forecast that one particular outcome will occur.

For a useful planning discussion, prepare two columns: obligations you have today and decisions that depend on future official action. Put current I-765 and EAD dates in the first column. Put school funding decisions and possible new fee requirements in the second.

Sources: Optional Practical Training Fees: October 8 proposed rule, sections V–VI; OPT fee proposal: original agency text and proposed transition provision

November 9 comment deadline: how to contribute useful feedback

The published notice sets November 9, 2026 as the deadline for comments on the rule itself. December 7, 2026 is a separate deadline concerning the information collection under the Paperwork Reduction Act. Do not substitute the later date for the main rule-comment deadline.

If you choose to comment, open the official Federal Register notice and use its Regulations.gov link for docket ICEB-2026-0100. Explain a concrete effect and the provision you are discussing. For example, describe how a prospective recommendation requirement could affect a graduation-to-training plan, and support financial claims with figures you can substantiate.

Comments can become public. Use a generalized account of your situation and remove unnecessary identifying details, receipt numbers, passport details, and personal documents. A public comment is not a private immigration case inquiry. You can also ask your university how it plans to provide institutional feedback.

Submitting a comment does not extend your status, pause an EAD expiration, or change an OPT filing deadline. Treat it as an optional contribution to rulemaking while continuing your own application preparations.

Sources: Optional Practical Training Fees: October 8 proposed rule, sections V–VI

A practical plan for the coming week

Start with a short appointment or written request to your international student office. Include your program end date or EAD expiration, the kind of OPT you expect to request, and the month you anticipate asking for the recommendation. Ask which dates and requirements the office can confirm today.

Keep a private folder with your I-20s, EAD, notices, and communications. TrackMyOPT can help you organize your existing OPT timeline and case-status milestones; it cannot promise a fee exemption or a university funding decision. The school and, when needed, qualified immigration counsel remain the right sources for your individual plan.

If a new official document appears, check its legal status and effective-date section before changing your plan. A comment extension, a press release, and a final rule are different events. The next meaningful update to this guide should identify the document, date, and practical consequence.

• Use the OPT application checklist
• Understand current STEM OPT employer requirements