STEM OPT Employer Requirements 2026: E-Verify, I-983 & Compliance Checklist

What Employers Must Know About STEM OPT

The 24-month STEM OPT extension (under 8 CFR 214.16) places significant obligations on employers — not just the student. Unlike initial OPT, where the employer has minimal regulatory responsibility, STEM OPT creates a structured training relationship with federal oversight.

As a STEM OPT student, you need to understand these requirements because your work authorization depends on your employer's compliance. If your employer fails to meet any of the following obligations, your STEM OPT could be terminated.

E-Verify Enrollment

Employer must be an active participant in E-Verify at the time of filing and throughout the STEM OPT period.

Training Plan (I-983)

Employer must co-develop and sign a formal training plan describing how the role provides STEM-related practical training.

Reporting Obligations

Employer must report material changes within 5 business days and submit evaluations at 12 and 24 months.

Wage Compliance

Employer must pay a salary commensurate with what similarly situated U.S. workers earn in the same role and location.

Supervision & Mentoring

Employer must provide structured oversight, not merely assign regular work duties.

E-Verify Enrollment: The Non-Negotiable Requirement

E-Verify is a web-based system run by USCIS and the Social Security Administration that allows employers to electronically confirm the employment eligibility of new hires. For STEM OPT, E-Verify enrollment is mandatory — there are no exceptions, waivers, or workarounds.

How do I check if my employer is E-Verify enrolled?

Ask your employer's HR department for their E-Verify Company Identification Number (a 4-7 digit number). You can also search at e-verify.gov or use TrackMyOPT's H-1B Sponsor Database which shows E-Verify status for 25,000+ employers.

What is an E-Verify Company ID Number?

This is a unique identifier assigned when a company enrolls in E-Verify. It must be listed on your I-983 form. Without it, your DSO cannot process your STEM OPT recommendation.

What if my employer is not enrolled?

Your employer can enroll in E-Verify at e-verify.gov — the process typically takes 1-2 weeks. However, if they refuse, you cannot do STEM OPT at that company. You would need to find an E-Verify employer before your initial OPT expires.

Does every company location need E-Verify?

The E-Verify enrollment must cover the specific worksite where the STEM OPT student will work. Some companies enroll all locations under one ID; others have separate IDs per site.

Important: If your employer loses E-Verify enrollment after your STEM OPT begins, they must notify you immediately. You then have 60 days to either find a new E-Verify employer or take other action to maintain status.

Form I-983: The Training Plan

The I-983 is the centerpiece of STEM OPT. It transforms the employer-employee relationship from a standard job into a structured training opportunity. Both you and your employer must complete and sign it before your DSO can recommend STEM OPT. For a detailed walkthrough of every section, see our complete I-983 guide.

Employer Sections

Company legal name, EIN, and address
E-Verify Company Identification Number
Detailed training objectives and goals
Supervision and mentoring plan
How training relates to the student's STEM degree
Performance evaluation schedule
Employer supervisor signature

Student Sections

Full legal name and contact info
SEVIS ID number
Degree program and CIP code
Student certification and signature
Acknowledgment of reporting requirements
Acknowledgment of employment conditions

The training objectives are the most scrutinized section. Avoid generic descriptions like "software development." Instead, be specific: "Developing predictive analytics models using Python, scikit-learn, and AWS SageMaker to forecast customer churn patterns." The more concrete, the better.

Employer Reporting Requirements

STEM OPT employers have ongoing reporting obligations that extend throughout the entire 24-month extension period. Missing these deadlines can jeopardize the student's immigration status.

Obligation	Deadline	Details
Material change report	Within 5 business days	Any change to employer name, address, EIN, supervisor, or student's job duties must be reported to DSO
Student departure/termination	Within 5 business days	If the student leaves, is terminated, or the role ends — employer or student must notify DSO immediately
12-month evaluation	At the 12-month mark	Employer completes a self-evaluation documenting the student's training progress and achievements
Final evaluation	At end of STEM OPT	Employer provides a final assessment of training goals. DSO submits to SEVP upon completion
Annual wage review	At each evaluation	Confirm compensation is still commensurate with U.S. workers in the same position and location

Validation reports: SEVP may send validation requests to employers asking them to confirm a STEM OPT student's employment. Failure to respond can result in termination of the student's STEM OPT authorization.

Wage Requirements

STEM OPT regulations require that the employer pay the student a wage commensurate with similarly situated U.S. workers. This prevents employers from using STEM OPT students as cheap labor and protects both the student and American workforce.

Commensurate compensation

Your salary must be comparable to what U.S. workers in the same metropolitan area earn for similar roles with similar experience. USCIS does not set a specific dollar amount — it is based on market rate.

How to verify fair wages

Check the Department of Labor's Online Wage Library (OWL) at flcdatacenter.com or use H-1B wage data from the LCA database. TrackMyOPT's H-1B Sponsor Database also shows median salaries by company and role.

Unpaid STEM OPT is generally prohibited

Unlike initial OPT where unpaid internships or volunteer work may count as employment, STEM OPT must be paid employment. The only narrow exception is bona fide volunteer work at nonprofits, but this does not count as STEM OPT employment.

Part-time minimum

You must work at least 20 hours per week. Compensation must still be commensurate on a pro-rata basis for part-time positions.

What If Your Employer Doesn't Meet Requirements?

If you discover your employer cannot meet STEM OPT requirements — whether they lack E-Verify, refuse to complete the I-983, or pay below-market wages — you have options. But time is critical.

Find a new E-Verify employer

You can change employers on STEM OPT. The new employer must be E-Verify enrolled, and you must submit a new I-983 within 10 days of starting the new position. There is no gap in work authorization during the transfer if done correctly.

Timeline: Report to DSO within 10 days

Ask your employer to enroll in E-Verify

E-Verify enrollment is free and takes about 1-2 weeks. Some employers are willing to enroll if they understand the process. Provide them the enrollment link: e-verify.gov/employers/enrolling-in-e-verify.

Timeline: 1-2 weeks for enrollment

Use the unemployment clock strategically

On STEM OPT, you have up to 150 total unemployment days (90 initial + 60 STEM extension). Use this window to search for a compliant employer, but don't wait until the limit is near.

Timeline: Track days carefully

Consider H-1B cap-gap or other status options

If you're approaching your STEM OPT expiration and employer issues persist, explore H-1B sponsorship, change of status, or other visa pathways before your authorization ends.

Timeline: Consult an attorney early

Consequences of Employer Non-Compliance

When an employer fails to meet STEM OPT requirements, the consequences affect both the student and the company. Understanding these risks can motivate reluctant employers to take compliance seriously.

Impact on Students

•STEM OPT work authorization can be terminated
•Unemployment clock begins ticking immediately
•Must find new compliant employer within 60 days
•Risk of accruing unlawful presence if no resolution
•May lose eligibility for future immigration benefits

Impact on Employers

•SEVP may flag the company for future audits
•Loss of ability to hire STEM OPT students
•E-Verify enrollment may be reviewed or terminated
•Potential DOL investigation for wage violations
•Reputational risk with international student community

STEM OPT Employer Compliance Checklist

Use this checklist to verify your employer meets every STEM OPT requirement. Share it with your HR department or hiring manager.

#	Requirement	Category	Priority
1	Employer is actively enrolled in E-Verify	E-Verify	Required
2	E-Verify Company ID Number is available for I-983	E-Verify	Required
3	Form I-983 completed with specific training objectives	Training Plan	Required
4	Employer supervisor has signed I-983	Training Plan	Required
5	Compensation is commensurate with U.S. workers (DOL data)	Wages	Required
6	Position is at least 20 hours per week	Employment	Required
7	Employer will report material changes within 5 business days	Reporting	Required
8	12-month evaluation scheduled and assigned to supervisor	Reporting	Required
9	Final evaluation planned for end of STEM OPT period	Reporting	Required
10	Employer will respond to SEVP validation requests	Compliance	Required

Key Employer Deadlines at a Glance

Stay on top of these critical deadlines. Missing even one can jeopardize the student's STEM OPT status.

Before filing STEM OPT

Employer confirms E-Verify enrollment, provides Company ID, and completes I-983 training plan sections with the student.

Within 10 days of changes

Report any material changes (job title, location, supervisor, duties, compensation) to the student's DSO. Submit a modified I-983 if needed.

Within 5 business days of departure

If the student is terminated, laid off, or leaves the company, notify the student and DSO immediately.

At the 12-month mark

Complete the midpoint evaluation assessing the student's progress against I-983 training goals. Student submits evaluation to DSO.

At the 24-month mark

Complete the final evaluation. DSO submits to SEVP. Discuss next steps (H-1B, new position, etc.) with the student.

When SEVP requests validation

Respond promptly to any validation inquiries from SEVP confirming the student's employment. Non-response can terminate authorization.

Frequently Asked Questions

Does my employer need to be enrolled in E-Verify for STEM OPT?

Yes. E-Verify enrollment is a non-negotiable requirement for STEM OPT employers. The employer must provide their E-Verify Company Identification Number on Form I-983, and enrollment must remain active throughout the entire STEM OPT period. If your employer is not enrolled, they can sign up at e-verify.gov — the process takes about 1-2 weeks.

Who fills out the I-983 form?

Both the student and the employer. The student fills in personal information (name, SEVIS ID, degree program), while the employer completes sections on company info, E-Verify ID, training objectives, supervision plan, and compensation. Both parties must sign the form before submitting it to the DSO.

What happens if my employer loses E-Verify enrollment?

If your employer's E-Verify enrollment is terminated after your STEM OPT begins, you have 60 days to find a new E-Verify employer and transfer your STEM OPT. Your employer is required to notify you immediately. Report the change to your DSO right away.

Can I change employers on STEM OPT?

Yes. You can change employers on STEM OPT, but the new employer must also be enrolled in E-Verify. You need to submit a new I-983 with the new employer within 10 days of starting the new position. Report the change to your DSO within 10 days as well. There is no separate USCIS filing required — the transfer happens through your DSO and SEVIS.

How often must employers evaluate STEM OPT employees?

Employers must complete two formal evaluations: one at the 12-month midpoint and one at the conclusion of the 24-month STEM OPT period. These evaluations assess training progress against the goals outlined in the I-983. The DSO submits these evaluations to SEVP. Missing evaluations can trigger compliance issues.

Key Takeaway

In This Guide