• Considering a US$100,000+ fee for post-study Optional Practical Training (OPT) placements. The OPT work stream is among US universities’ top competitive strengths when recruiting talented international students, and research shows that more than half of international students would not choose the US if they could not access it.



• Applying greater scrutiny to Curricular Practical Training (CPT) placements, as articulated in two broadcast memos issued by the Immigration and Customs Enforcement department (ICE) on and . CPT allows a student (domestic or international) offered by a sponsoring employer through a co-operative agreement with the student’s school.

In the memos, ICE says that the Student and Visa Exchange Programme (SEVP) is showing an uptick in “CPT authorisations that do not meet regulatory requirements, specifically those not constituting an integral part of an established curriculum.” The insinuation here is that some institutions are promoting CPT as a general work route rather than as an essential curriculum requirement. The department warns: “If SEVP suspects that school officials are abusing CPT to create work opportunities rather than academic studies, they may be subject to additional scrutiny and action from SEVP and Homeland Security Investigations (HSI), to include potential withdrawal of the school’s SEVP certification.”

The department cautions: “In any instance where an elective course is optional, making the CPT optional, the integral and required aspects of CPT would not be met … [CPT should be authorised only] if its absence would make the attainment of a degree an impossibility.”

The power of rhetoric

The State Department has neither imposed the US$100,000 OPT fee nor amended the CPT programme through law. However, the department is clearly communicating its concern around both programmes, and this is serving a two-fold rhetorical purpose:

• To warn prospective international students that access to work in the US is far from certain for them;
• To discourage universities from linking academic programmes with work routes in their promotional or operational activities.

Most universities are pausing their authorisation of elective CPT programmes while continuing their curriculum-linked CPT. Even though the memos are, as Carnegie Mellon has called them, “extra-regulatory,” they carry enforceable actions. If a university were be seen to be abusing the CPT system, it could have its SEVP certification removed and would thus be barred from enrolling international students.

Even though the guidance will be a concern for all universities and colleges, the cautions from ICE may be especially aimed at a small group of US institutions that are colloquially known as “” universities, and where the promotion of work-integrated learning via CPT placements is . The critique that attaches to such institutions is essentially that they are over-promoting or overusing CPT, and providing a mechanism for students to bridge visa status while they remain in the US in the hopes of transitioning to an H-1B visa or otherwise preserving their ability to work in the country.

A layered approach

A potential OPT fee and CPT warnings are just two layers of the Trump administration’s mission to limit opportunities for international students in the US. On 15 September, the new rule replacing Duration of Status (D/S) with an Admit-Until-Date (AUD) system comes into force. For those needing background on the importance of this change, we have covered this extensively over the summer, including in this article.  

The imminent end of D/S has created additional uncertainty for US universities attempting to update systems and advise students, and it appears to have already dampened demand for study in the US. International enrolments declined in 2025, especially in graduate programmes.

Graduate programmes “in crisis”

In July 2026, reported on the effects of the Trump administration’s approach to immigration and to higher education and science in general:

• “Cornell University enrolled 209 fewer new grad students last year, with declines across nearly all of its schools.
• Michigan State University paused admissions to most of its advanced programs in the humanities for a year to assess them for “long-term sustainability.”
• Massachusetts Institute of Technology has been shaken by a 20% drop in the federally funded research that made its graduate programs into an innovation powerhouse.”

Bloomberg interviewed Chevelle Newsome, president of the Council of Graduate Schools, who said that graduate schools are in a “crisis response” mode that “will take decades to recover from.”

Perception influences behaviours

For most research universities, restricting CPT as per ICE’s guidance is not a big deal. At prominent institutions such as UCLA, less than a quarter of international students participate in CPT – a fraction compared with the number participating in OPT. But what is a big deal is that international students are hearing that both OPT and CPT are under greater scrutiny. The government is creating a perception that work opportunities in the US are diminishing without even having to pass laws to that effect.

There are important developments on the horizon that aim to counter that perception by curbing the government’s ability to implement more restrictive policy. For example, NAFSA and seven other educational and business organisations have filed a complaint to halt the implementation of the fixed-term admission period for international students and other visitors.

The consortium is challenging the legality of the rule and has also filed a motion for a preliminary injunction that aims to prevent the rule from coming into effect. The request for an injunction will be heard in court in early September.

In addition, the upcoming mid-term elections (3 November 2026) may provide for some further balance in the US system. Amid rapidly deteriorating approval ratings for President Trump, that the mid-terms will return control of the House of Representatives to the Democrats. This would give the House more ability to counter executive action from the White House, including those concerning education and immigration.

Key developments for the new academic year

As of this writing on 3 September 2026:

• CPT: The Department of Homeland Security says, “Nothing about [CPT] regulations has changed. However, schools and employers should consider themselves on notice: under President Trump, abuse of this generous system will no longer be tolerated.”
• OPT: A new rule on OPT was on the agenda for 2026 but is now slated for publication in February 2027. A $100,000 OPT participation fee is under discussion, but it has not transitioned to the proposal phase.
• Duration of Status: Duration of Status (D/S) will be replaced by Admit-Until-Date (AUD) on 15 September unless a preliminary injunction is delivered before then. Current international students who have not returned to the US before that date will be subject to AUD despite first enrolling under Duration of Status terms. 

For additional background, please see:

• “US Department of State issued 23% fewer study visas to international students in 2025”
• “Updated: US Department of Homeland Security publishes rule to end Duration of Status for international students“
• “US coalition files lawsuit to challenge rule ending Duration of Status admissions for international students“
• “Report: US considering a $100,000 fee for Optional Practical Training” 

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China and India

US colleges’ top two markets, China and India, saw steep declines of -28% and -57%, respectively. This has massive implications: For years, Chinese and Indian students have composed more than half of the total international student body in the US. Many colleges remain incredibly dependent on the continued flow of these students into their programmes despite efforts to recruit across a wider range of countries.

Diversification interrupted

To complicate matters, diversification is becoming more difficult because students in several growth markets are banned from entering the US (e.g., Nigeria) or are experiencing high visa rejection rates (e.g., Ghana and Nepal). It is no coincidence that:

• Visa issuances to Ghanaian and Nepali students dropped by -52% and -55%, respectively, in 2025 compared with 2024;
• The CommonApp platform (which receives a large number of all international applications to US colleges) registered fewer applications from Asian and African students, respectively, for 2025/26 programmes. The percentage drop was -34% for applications from Ghana.

Slow visa processing is also hitting the applications pipeline and causing stress for institutions and students alike.

The importance of the Indian decline

The huge drop in Indian visa issuances is particularly difficult for US graduate/STEM programmes. The number of Indian students pursuing graduate degrees is the number in undergraduate programmes.

Trends for India have been worrisome for some time. For example:

• More than 6 in 10 (61%) Indian students were rejected for a visa in the US in 2025;
• The vast majority (61%) of institutions participating in the survey for the IIE’s 2026 Spring Snapshot on International Educational Exchange said Indian application volumes had declined.

The decelerating trend for India will almost certainly continue. A new rule from the Trump administration abolishes the decades-old Duration of Status (D/S) system that among other things, allowed students to progress from F-1 academic studies to the Optional Practical Training (OPT) work stream. The new system requires students to ask for a visa extension from immigration authorities after they have been in the US for four years, with no guarantee they will be approved. Virtually all students will need an extension to participate in post-study OPT since it happens after the completion of four years of study.

A total of in 2024/25 – accounting for . The end of D/S – if it happens, since plaintiffs including NAFSA are now challenging this in court – will remove a key driver of Indian student mobility to the US.

The following chart was created by International Data & Recruitment Strategist Dave Amor, who posted it on LinkedIn. Mr Amor illustrates the decline of total F-1 visa issuances in the past year – and the extreme drop for the Indian market.

Broad implications

Earlier this month, based on the application trends reported by US colleges in the Institute of International Education’s (IIE) Spring Snapshot survey. NAFSA projects that there will be up to 111,000 fewer international students at US higher education institutions in 2026/27, resulting in close to US$3.4 billion in lost revenue and nearly 40,000 job losses. 

For additional background, please see:

• “Visa delays and policy uncertainty projected to reduce foreign enrolment in the US by more than 100,000 students this fall“
• “Decline in Indian demand a major factor in softer outlook for foreign enrolment in US higher education in 2026/27“

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A preliminary injunction is a formal request asking a court to issue a temporary order early in a lawsuit – before the case is fully decided – to require someone to do something, or, as in in this case, to stop doing something. The goal of this filing is to compel the government to halt its implementation of the rule replacing D/S with a fixed visa permission of up to four years. After the limit is reached, students and visitors must apply for an extension to US immigration authorities. The final rule is meant to come into effect on 15 September 2026.

Parties to the legal challenge are:

• NAFSA: Association of International Educators
• The Presidents’ Alliance on Higher Education and Immigration
• The Association of Independent Colleges and Universities in Massachusetts (AICUM)
• The American Federation of Teachers (AFT)
• Graduate Labor Organization, AFT Local 6516 (GLO)
• International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)
• United Auto Workers Local 2322
• The NewsGuild-CWA

“Ending Duration of Status and imposing new limits on academic decision-making is a solution in search of a problem,” said NAFSA CEO and executive director Dr Fanta Aw. “The rule will severely undermine the contributions international students make to US campuses, economies, and national security. After carefully reviewing the final rule and the sweeping harm it will cause to our national interest, it is clear that litigation is warranted and necessary.”

McDermott Will & Schulte will represent the plaintiffs in the U.S. District Court for the District of Massachusetts.

Background

The D/S system was in place for decades, and it allowed international students to stay in the US to complete their full academic programme as well as to gain three years of post-study work experience. For more background on what the end of D/S means for students, universities, and businesses, please see our comprehensive article here.

Miriam Feldblum, president and CEO of the Presidents’ Alliance on Higher Education and Immigration says:

“This rule upends the longstanding Duration of Status framework that has allowed international students and scholars to pursue their educational programs while maintaining lawful status. By placing time limits that do not align with actual program lengths or students’ educational needs and shifting crucial academic decisions from institutions to immigration officials, the rule will disrupt educational pathways, impose significant new burdens on colleges and universities, and make the United States less competitive as the premier destination for global talent. We are going to court to protect international students and scholars and to defend our member institutions’ ability to educate, train, and retain them.”

What is the basis for the challenge?

The consortium argues: “The final rule violates the Administrative Procedure Act because DHS failed to adequately assess its costs and benefits, meaningfully respond to public comments, consider less burdensome alternatives, or justify the rule based on its stated objectives. It also alleges that DHS provided an inadequate public comment period and exceeded its statutory authority.”

“The United States once again is breaking the law for its own political purposes and, in doing so, is hurting Americans and American enterprise,” argues AFT President Randi Weingarten. “And it’s using international students – who we’ve welcomed here to help us – as its pawns. America is a leader in cutting-edge research because generations of scientists from every corner of the globe have been free to pursue difficult questions, challenge conventional wisdom, collaborate openly and publish their findings – without political interference. This latest assault on knowledge by the Trump administration arbitrarily limits how long international scholars have to complete their studies and risks turning a welcoming environment for students into a hostile one. We stand united with our higher education members, international and American alike, so they can continue to make US colleges and universities the envy of the world.”

What is at stake?

The plaintiffs explain: “These changes will create significant uncertainty and administrative burdens for international students and exchange visitors and the institutions that support them. They will also interfere with academic decision-making, disrupt students’ educational and professional plans, and undermine the ability of U.S. colleges and universities to attract and retain global talent.”

Robert McCarron, president and CEO of the Association of Independent Colleges & Universities in Massachusetts, comments:

“More than 80,000 international students come to Massachusetts to pursue higher education, adding vibrancy and innovation to our campuses and often founding startups in Massachusetts. These students and researchers drive innovation, pursue life-changing research, and create more than $4 billion annually in economic impact in Massachusetts. The litigation seeks to ensure that such profound changes to the rules governing international students and others comply with applicable legal requirements and reaffirms that Massachusetts continues to welcome talented students and researchers from across the globe.”

What happens next?

Legal observers expect that the court will take up the coalition’s request for emergency relief, which, if successful, would prevent the rule from coming into effect on 15 September.

The immigration law firm Fragomen notes in its guidance that, “Prospects for the lawsuit are uncertain, and employers and foreign nationals should continue to prepare for the scheduled implementation of the new regulation on September 15 in the event the plaintiffs’ efforts to obtain an emergency stay are unsuccessful.”

For additional background, please see:

• “Updated: US Department of Homeland Security publishes rule to end Duration of Status for international students”

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They are Bridge Mills Galway Language Centre, Emerald Cultural Institute, International House Dublin, Liffey College, and Patrick’s English Academy.

Those five schools now join that have to date also been awarded the mark.

The announcement of the first language school awards, said Dr Lynn Ramsey, CEO of QQI, “marks a new era of quality oversight and regulation for the English-language education sector in Ireland, with the establishment of formal, statutory engagement with QQI. Under the scheme, QQI has a statutory monitoring responsibility to ensure providers adhere to the agreed code of practice, ultimately ensuring that the rights of learners are protected during their time studying in Ireland.”

An accompanying statement from QQI provides important background: “To obtain TrustEd Ireland authorisation, [ELT] providers must undergo a thorough due diligence assessment, which examines areas such as financial and legal structures and business plans to establish the capacity and capability of private education providers to deliver quality assured education programmes.

“Under the scheme, providers must also have quality assurance procedures that are approved by QQI and demonstrate compliance with an associated Code of Practice.” (Note that there are distinct Codes of Practice for and for .)

Replacing the ILEP

The continued expansion of the TrustEd Ireland scheme has additional significance beyond its role as an official quality mark. First, the provisions for the mark are enshrined in Irish legislation. QQI’s powers to assess and monitor providers and to enforce the requirements of the scheme also arise from that legislation.

Second, the TrustEd Ireland mark will shortly become the basis for determining whether or not an Irish institution or school is eligible to recruit non-EU students. In other words, it functions as a licence to operate in the international student market, at least in terms of recruitment of non-EU/EEA students that require a visa to study in Ireland.

The current mechanism for this is the Interim List of Eligible Programmes (ILEP), which is maintained by the Department of Justice’s Immigration Service Delivery. The ILEP, however, will shortly be superseded by the TrustEd Ireland scheme.

First announced in 2024, an initial window for applications for the TrustEd Ireland mark opened from 14 October 2024 to 28 March 2025. A second window was opened from 13 October 2025 to 27 March 2026, the decisions from which are expected by the end of this year.

After that point, the ILEP will be replaced by a new TrustEd Ireland Authorised Providers: List of Eligible Programmes. QQI explains: “The new TrustEd Ireland list will identify those programmes that comply with immigration requirements to enable Immigration Service Delivery (ISD) in the Department of Justice, Home Affairs & Migration to determine applications for study visas and immigration permissions for study purposes.”

“All education providers intending to recruit non-EU/EEA/Swiss students that require study visas or immigration residence permissions for the purpose of study (where such residence exceeds 90 days) must ultimately secure authorisation from QQI to use the TrustEd Ireland mark.”

For additional background, please see:

• “Ireland to open applications for new quality assurance mark in September 2024“
• “Ireland’s ELT sector reports modest growth in student numbers but weeks are down amid ‘real and consequential’ challenges“
• “Irish higher education reports a fourth straight year of foreign enrolment growth“

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Representatives from more than 150 Canadian language programmes (English and French) responded to both the 2024 and 2025 editions of the survey, providing an analytical basis from which to compare trends in both years. The topline finding is that the number of students decreased by -13% and student weeks by -19% between 2024 and 2025.

Just over 81,600 students were enrolled in language programmes in 2025 (92% in English, 8% in French), collectively spending about 798,900 weeks in their studies.

The following chart from the report shows that the marked downward trend in student weeks began in 2023/2024. The language training sector is now roughly half the size it was in the year before the COVID-19 pandemic.

The value of the sector

Canada’s immigration policies have had a pronounced negative impact on international student numbers in Canadian institutions – and a much greater impact than the government anticipated. The result has been devastating for many institutions across levels and sub-sectors, but especially for language-training providers, which receive far fewer study permit allocations than universities do. In the foreword to the Languages Canada report, Gonzalo Peralta, the association’s executive director, notes:

“These policy decisions have significantly reduced enrolments, forcing programs to scale back operations and, in some cases, close entirely.

“While economic uncertainty and increased international competition contributed to the downturn, it is the policy environment that most decisively undermined the sector’s stability and growth. The consequences are felt across the country, with institutions struggling to maintain viability and communities losing the economic and cultural benefits these programs provide.”

What is at stake is not only the sustainability of the sector, but also millions of dollars. Languages Canada reports:

“Even amid this crisis, Languages Canada members contributed an estimated CDN$1.03 billion directly to the Canadian economy in 2025 – representing direct economic activity, much of it generated through export revenues – highlighting the sector’s enduring value.”

The estimated economic impact of the sector decreased by -1% in 2025 versus 2024.

Top 10 markets

Japan is the main sender of students and by far the largest contributor of student weeks. The top 10 markets for Canadian language programmes (with numerical values in the chart below) are:

• Japan
• Brazil
• South Korea
• Mexico
• Canada (Canadian students studying French or English in their own country)
• China
• Colombia
• Taiwan
• France
• Italy

All markets are down – some of them significantly – other than Canada, which is relatively stable. This fact alone highlights the damaging effect of immigration policies that of course do not affect Canadian students applying to their own country’s language programmes.

Destination comparison

The Canadian language training sector is not alone in facing difficult trading conditions. In terms of student weeks – a more indicative source of volume for language programmes than student numbers – the change between 2024 and 2025 was -8% in the US, -10% in the UK’s private sector, and -18% in Ireland.

In Australia, official data on student weeks for the English-language (ELICOS sector) has not yet been released, but:

• ELICOS’s share of total international enrolments nearly halved between 2023 and 2025 (from 16.6% to 8.8%);
• Student numbers fell from 97,200 in 2024 to 60,850 in 2025;
• Visa applications for ELICOS study dropped by -39% in 2025 versus 2024.

Similar to Canada, Australian government policies are the major contributor to the sector’s troubles. In Canada, the issue is the student cap that disproportionately affects language providers. In Australia, the main depressor on demand is the steadily rising visa application fee, which now stands at AUS$2,050 for English-language applicants. Applying for an Australian study visa is now roughly as expensive as a short English-language course of 10 weeks – and the application fee is non-refundable for students who are rejected for a visa.

Languages Canada vows to continue lobbying

Writing in the Languages Canada report, Mr Peralta says:

“While the findings present a stark and candid assessment, Languages Canada remains committed to working with its members and partners to advocate for the changes needed to stabilise and rebuild Canada’s English and French language education sector, support learners from Canada and around the world, and ensure that these essential programs can survive and recover.”

For additional background, please see:

• “US: ELT weeks fell by nearly 8% in 2025”
• “UK’s ELT sector reports declining enrolments through first quarter of 2026”
• “Ireland’s ELT sector reports modest growth in student numbers, but weeks are down amid ‘real and consequential challenges’”
• “Australia: Full-year data for 2025 reveals impact of AUD$2,000 study visa fee on ELICOS sector”
• “Canada’s language training sector reinvents pathway programme model in response to policy settings”

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This is the most serious sanction that can be levelled against a licensed sponsor. Revocation of the sponsor licence means that Bloomsbury, formerly the London School of Business and Management, immediately loses the ability to sponsor international students under the UK’s Student Route.

This means that it can no longer issue Confirmation of Acceptance for Studies (CAS). Any CAS already issued also now becomes invalid, and any pending visa applications based on a Bloomsbury CAS will be refused. The Institute will also be removed from the Register of Student Sponsors.

The revocation of the Bloomsbury Institute’s sponsor licence on 5 August 2026 follows the suspension of its licence on 9 June 2026, from which point it was forced to also suspend recruitment of international students.

The Institute’s licence was in the balance this year because Bloomsbury had not maintained compliance with the Basic Compliance Assessment (BCA) requirements. As the Home Office explains: “The Basic Compliance Assessment is an annual check that all sponsors must pass, measuring visa refusal rates, course enrolment and completion.”

Those BCA thresholds tightened this year, but Bloomsbury was assessed against the earlier benchmarks, which required that all sponsors maintain a visa refusal rate of less than 10%, an enrolment rate of at least 90%, and a course completion rate of at least 85%.

“Student sponsors must meet the standards required to retain their licence,” said the Home Office. “Failure to meet these standards represents a serious breach of its duties as an international student sponsor, and as a result, [Bloomsbury’s] licence was revoked.”

Effective 1 June 2026, the BCA thresholds were further strengthened such that visa refusal rates must be maintained below 5%; the course enrolment rate must be at least 95%; and the course completion rate must be at least 85%. Perhaps unnecessarily, the Home Office notes as well that, “The Bloomsbury Institute would also have failed to meet the new, stricter standards.”

A largely international student body

For 2024/25, the most recent available reporting year, HESA data indicates that the Bloomsbury Institute enrolled a total of 1,035 students. More than 800 of those, or nearly 80%, were international students, with the lion’s share (93%) coming from Pakistan.

The revocation of the sponsor license necessarily places the study programmes of those students, and even the future of the institution, in question. The Home Office says that its priority now is to “minimise disruption for international students already enrolled” at Bloomsbury.

To that end, the Institute “will be permitted to continue teaching its current sponsored students for a short period,” the term of which is not specified. Students who cannot complete their studies within that window will be supported to transfer to another institution.

Needless to say, those provisions are an important feature of the Home Office announcement. The headline is that a UK institution has had its sponsor licence revoked. But of course, behind that headline, are the many affected staff and students who now must deal with the uncertainty that accompanies this sanction against their institution.

For additional background, please see:

• “Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment“
• “UK universities bracing for a further decline in international enrolments“
• “England: Government ‘remains of the view’ that the International Student Levy should go ahead; implementation planned for August 2028“
• “UK: Sponsored study visa issuances down, rejection rates up, and more“

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Based on institutional responses in IIE’s , the estimate is for a 9.5% decline in overall foreign enrolment in the US in fall 2026. This could result in . In economic terms, that translates to up to US$3.4 billion in lost spending and 39,000 jobs affected.

“The projections underscore what we’ve long warned,” said Fanta Aw, Executive Director and CEO of NAFSA. “US policy and regulations affect where international students plan to invest their future—and their decisions carry significant short- and long-term consequences for US society and economy, All Americans lose when international students and scholars are driven to more welcoming countries.”

Where is this coming from?

The analysis points to three major factors behind the projected decline in enrolment for 2026/27: reduced or diverted demand; process and policy around student visas; and policy uncertainty.

There are a number of indicators of declining demand for study in the US this year, whether those students are simply deferring their study plans or choosing an alternate destination. First, recent findings from the highlight that the international pool of doctoral candidates shrunk by -21% for 2026/27, a trend that led to an overall decline in international PhD admissions of -17%. Meanwhile, says that international applications filed via its college admissions platform are down -9% for the coming academic year. And, as we reported recently, nearly two-thirds of respondents to IIE’s Spring Snapshot Survey are expecting enrolment declines for 2026/27.

Those trends are no doubt influenced by a series of underlying issues around student visa processing. An expanded ban on travel to the US affecting citizens from 39 countries, including Nigeria, has been in place since 1 January 2026. While there has not been an outright pause on visa processing this year, the State Department’s prioritisation of visa processing for FIFA World Cup ticket holders traveling to the US supplanted the historical norm of prioritising student applicants during the peak processing months over spring and summer. Making the situation even more challenging, there are widespread reports of significant processing delays and in India, China, and Europe.

Finally, both announced and anticipated rule changes are combining to create additional uncertainty for international students in the US this year. A new rule will come into effect on 15 September 2025 to replace the longstanding “Duration of Status” framework with a fixed Admit-Until-Date (AUD). The new AUD mechanism sets a maximum limit for which a student visa can be granted, and requires continuing students to apply for an extension with US immigration officials. This, says NAFSA, creates “significant planning uncertainty for prospective students, particularly those considering longer-degree programmes,” and an issue which is compounded by “the current administration’s continued warnings that it intends to reform the Optional Practical Training programme.”

The need for speed

“Forfeiting the US position as the top destination for global talent hurts students, hospitals, research laboratories, the economy – and carries the real risk that the next big invention will not happen on US soil,” adds Dr Aw. “We urge the administration and Congress to take swift action to ensure international student contributions continue to benefit American ingenuity, economic prosperity, and national security.”

In order to ease the projected decline for 2026/27, NAFSA is urging the US administration to take the following steps.

• Prioritise processing for all F and M visa applicants as well as for those pursuing a J visa for exchange in the US;
• Exempt students and exchange visitors from the current travel ban “while maintaining background checks and vetting required for visa issuance”; and
• Preserve Optional Practical Training for foreign graduates in the US.

For additional background, please see:

• “Decline in Indian demand a major factor in softer outlook for foreign enrolment in US higher education in 2026/27“
• “Updated: US Department of Homeland Security publishes rule to end Duration of Status for international students“
• “US regulatory agenda for 2026 aims to end ‘duration of status and introduce Optional Practical Training and H-1B reforms“
• “US extends travel ban, Nigeria now included on ‘restricted’ list“

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The hefty fee would apply to post-study Optional Practical Training (OPT) placements. Post-study OPT is the work stream that allows students who complete a minimum four-year bachelor’s degree to gain one to three years of work experience related to their field of study, and it often serves as a bridge from F-1 student status to at least three years in a formal position with a US employer on an H-1B visa. Three-year OPT is reserved for students with STEM degrees.

More than 294,000 students participated in OPT in 2024/25 – representing about one in four international students in the US. This was a 21% increase over the previous year.

Any move to limit access to OPT will upend foreign students’ estimation of the return on investment for study in the US. A recent Chronicle of Higher Education survey found that 8 in 10 international students would not choose to study in the US if they could not access OPT.

Nothing is certain yet

A Department of Homeland Security (DHS) spokesperson confirmed that the fee is under discussion, but it stressed in a statement to the paper that “no policy should be considered final until it is formally announced.” It is not clear yet who would have to pay the $100,000 OPT fee – students, universities, or employers.

OPT under fire

For decades, international students were permitted to stay in the US for as long as their study journey required, including three years of OPT participation, under a rule called Duration of Status, or D/S.

But a 2025 administration proposal to put fixed limits on international students’ legal status in the US will become a rule in September 2026. International students will have to leave after four years unless they submit, and are approved for, an extension by immigration officials.

This makes a potential $100,000 OPT fee even more off-putting to international students. Not only will they need to submit a request to US Citizenship and Immigration Services (USCIS) to stay in the US for longer than their length of their degree – with no guarantee they will be approved – but the $100,000 fee would make it even less likely that they would (1) be hired (if the fee were levied on employers) or (2) afford to be hired (if students themselves had to pay the fee).

If at first you don’t succeed …

It is quite possible that the government views a steep OPT price tag as a satisfactory equivalent to its September 2025 proclamation requiring employers to pay a $100,000 fee to sponsor a foreign worker for an H-1B visa. That ruling was later blocked in court. The administration submitted an appeal to reverse the decision, but a federal court rejected the appeal on 24 July 2026.

If the administration were to push through the $100,000 fee for OPT submissions, it could achieve the same goal as the as-yet unsuccessful H-1B fee of blocking a huge proportion of international graduates and skilled foreign workers from employment in the US.

Brain drain from the US is already happening

The potential for brain drain is real. The WSJ notes: “Advocates contend that without OPT, most international students would be forced to leave the country immediately after graduation, pushing them to take the skills they gained at American universities to foreign markets.”

Destinations such as Germany, France – and the US’s great-power rivals China and Russia – are already benefitting from lower student demand for the US. All these countries – and several more alternative destinations – are building their foreign enrolment at the same time as new international student commencements in the US (as well as in Australia, Canada, and the UK) decline.

The impact on universities and employers

International students’ contributions are vital to STEM-based sectors and to US innovation in general. For example, a 2025 Silicon Valley Index report found that 66% of technology workers in the region are foreign born.

The potential impact on Indian and Chinese enrolments

If enough Indian and Chinese students decide to stay away from the US, it could be a devastating revenue hit for many US colleges. More than half (53%) of all international students in academic programmes or OPT in the US are Indian or Chinese.

Doctoral-degree-granting institutions would be especially affected. Consider:

• Eight in 10 Indian students studying in the US in 2025 – and nine in 10 Chinese students – are enrolled at a doctoral college.
• Of 57,800 PhDs granted to all students in the US in 2023, 19,400 (34%) were awarded to F-1 international students, nearly half of whom (44%) were Chinese or Indian.
• Chinese and Indian students received nearly one-sixth (15%) of all PhDs awarded by US institutions in 2023.

It isn’t too dramatic to say that R&D innovation in the US would be significantly affected by a major fall-off in Indian and Chinese demand.

The Indian and Chinese flow of OPT students to US employers would also be severely impacted:

• Of all Indian students in the US in 2025, 40% were in OPT. This represents a near doubling of the proportion the previous year.
• Of all Chinese students in the US in 2025, 23% were in OPT.

Change is coming

Whether or not a $100,000 OPT fee comes into being, what is certain is that the Trump administration is currently considering new rules for OPT. There are few details at present, but new OPT rules are slated for introduction in February 2027. The government has indicated only that it will “amend existing regulations to address fraud and national security concerns, protect US workers from being displaced by foreign nationals, and enhance the Student and Exchange Visitor Program’s capacity to oversee the program.”

Lawsuits highly likely

Multiple lawsuits arose to fight the H-1B fee, and the fee has been declared unlawful. As of this writing, US employers do not have to pay the fee to hire international students or foreign skilled workers.

Litigation is already in process to contest the fixed admission rule set to come into force on 15 September 2026.

As reported by Forbes, “legal consultations have left experts questioning the administration’s lawful authority to impose a $100,000 OPT fee.”

For additional background, please see:

• “US regulatory agenda for 2026 aims to end ‘duration of status’ and introduce Optional Practical Training and H-1B reforms”

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