• 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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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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The “” is interesting in part because it is the fourth such effort to build a picture of industry practices around managing education agency partnerships, following earlier survey cycles in 2018, 2023, and 2025.

AIRC reports that, across all four surveys, US educators’ engagement with agencies has increased (from 62% in 2018 to 75% this year). The survey also found that US institutions and schools are moving away from commissions based on gross tuitions in favour of agreements based on net tuitions or fixed referral fees.

More specifically, the most common commission structure among this year’s respondents is a fixed post-enrolment fee (48%), whereas nearly four in ten responding institutions (39%) said they relied on a commission calculated as a percentage of net tuition. (In such cases, net tuition reflects the gross tuition adjusted for scholarships and grants.) As of this year’s survey, only 6% of responding institutions said that they still base commissions on gross tuition.

In terms of the actual commissions paid:

• For institutions that pay based on gross tuition, the most frequently reported commission rate was 15%;

• For institutions relying on net tuition, most reported commission rates of 10%–15%;

• For those that pay a fixed-rate commission, most reported per-capita payments of $2,000–$3,500.

AIRC adds: “Several institutions utilise tiered models, where the percentage changes based on volume, student type, or year of enrollment. For example, one institution pays 15% for the first 30 students and 20% for students 31+, with two agencies starting at 20% and escalating to 25%. Several institutions pay a higher rate for the first year (e.g., 10% or 12% for year 1) and a reduced rate for subsequent years (e.g., 5% for year 2 and beyond, or 8% for year 2, 4% for year 3, and 2% for year 4).”

The survey also highlights that two-thirds of respondents (67%) do not issue commission payments until all tuition and other fees have been received. Another 21% will process commissions once all tuition fees have been received (excluding housing or any other fees).

Just over half (51%) indicated that they provide commissions for the first two semesters of enrolment. Nearly one in five (18%) pay commissions on the first semester only; and another 13% said that they pay commissions on the first three or four semesters. The remaining 18% said that they pay for more than four semesters.

Beyond commissions

“Institutions are investing more in agency relationships through webinars/training (72%), application support (66%), in-country visits (64%), and recruitment event participation (62%),” adds AIRC.

“When asked about new and creative initiatives that institutions have implemented to effectively work with their agency partners, the majority of institutions focus on enhanced communication and engagement, incentives and structure, and operational streamlining. Efforts include frequent, direct communication with agency partners, regular in-country visits, tiered commission structures, or granting agents limited access to the institution’s CRM.”

The survey findings otherwise make it clear that most institutions are actively exploring ways to strengthen their agency partnerships, including more frequent communication, and plans to add staff to build and support agent relationships.

For additional background, please see:

• “Updated: US Department of Homeland Security publishes rule to end Duration of Status for international students“
• “Decline in Indian demand a major factor in softer outlook for foreign enrolment in US higher education in 2026/27“

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As expected by US international education experts, the Department of Homeland Security (DHS) has made only minor revisions to its August 2025 proposal to end Duration of Status (D/S) for F and J students and their dependants despite vigorous lobbying across scientific, business, and higher education sectors. The government published , and it will go into effect on 15 September 2026.

Duration of Status will be replaced with fixed periods of stay for F and J students – four years – unless students are in language programmes, the admission duration for which will be maxed at 24 months. (For detailed background on the policy, please refer to our earlier reporting.)

To stay in the US for longer than the end date marked on their I-94 form, international students need to apply and be approved for an extension by US Citizenship and Immigration Services (USCIS). If they do not receive that extension, they will have to leave the US or be identified as unlawful and subject to a three-to-ten-year ban on re-entering the US.

There is no grace period for four-year F and J students after an extension of status denial at the end of the initial admission period: students and any dependents who may have come to the US with them are required to depart immediately. If not, the next day marks the official beginning of their unlawful presence in the US.

Commenting on the new rule, NAFSA Executive Director and CEO Dr Fanta Aw said:

“DHS’s decision to end Duration of Status is a misguided and unnecessary policy shift that injects uncertainty, bureaucracy, and fear into a system that has long worked effectively. It is a solution in search of a problem. International students and exchange visitors are already the most monitored nonimmigrant populations in the United States. SEVIS and the partnership between institutions and the federal government already provide a rigorous and highly effective system of oversight, compliance, and accountability.

“This rule introduces unnecessary government intrusion into academic decision-making. Requiring students and scholars to seek approval to extend their academic program, change majors, or pursue the next level of study places life-changing educational decisions in the hands of an already overburdened immigration system rather than educators and institutions.

“At a time when global competition for talent is intensifying, this policy sends exactly the wrong message. It tells the world’s brightest students and scholars that the United States is becoming less welcoming, less predictable, and less committed. This is not just bad for higher education, it is bad for American innovation, economic growth, workforce development, and global leadership.”

What will the new rule mean for universities, agents, and students?

Universities and agents: The incoming rule will raise many questions for educators and agents who will be pressed to advise students properly. NAFSA explains:

“There are��transition provisions��for F and J nonimmigrants who were admitted for D/S on their Form I-94 and are inside the United States on September 15, 2026, the final rule effective date. These individuals will not have to immediately apply for a date-certain I-94, but they must still apply for an extension of stay in order to remain in status beyond the program end date on their current Form I-20 or DS-2019, or four years from the final rule effective date, whichever is shorter, and will also be subject to the new academic restrictions in varied ways. If someone in this transition group exits the United States and reenters on or after September 15, 2026, CBP will readmit them with a Form I-94 with a date-specific AUD.”

New international students who had planned to begin programmes this fall may now decide not to. Two segments are at particular risk of reconsidering their decision to study in the US:

• Those for whom the opportunity to pursue Optional Practical training (OPT) after their studies was central to their decision to choose the US as a destination. They now know that the maximum period of admission on an F or J visa is about to be four years, which means they would need to apply for an extension to go on to OPT – an extension that might be rejected.
• Graduate-level students, who will realise that four years may not even cover the length of their programme, let alone OPT.

The OPT and STEM OPT post-study work streams are vital to US institutions’ ability to compete for international students (especially those in STEM and at the graduate level). A 2025 survey conducted by NAFSA and the Institute for Progress found that 54% of current international students would not have chosen the US if there was no OPT option.

Current international students: Current F and J students will live in a climate of uncertainty: many will be required to apply for a visa extension before graduation, knowing that they could be denied that extension. This would mean that their studies in the US would be over the day after they were refused an extension. They would not be able to finish their degree in the US.

Additional components of the new rule bar F and J students from changing academic programmes, and graduates who complete one academic programme will only be able to enrol in a new one if it is at a higher educational level.

What is the context for the introduction of fixed admission periods?

At present, USCIS’s processing of immigration requests has never been more backlogged. Adding international students’ requests for extensions to the backlog will only worsen the situation. Many students will face a long wait to see if their extension is approved. 


��
The granting of extensions will be in the hands of immigration officials at a time when the US government is eager to reduce the flow of foreigners into the country.

How best to advise students and brief student advisors?

The immediate priorities for many US institutions and stakeholders leading up to the September effective date will include:

• Retraining staff on the rule’s key concepts and new terminology (e.g., “admit until date” [AUD])
• Reviewing all programme types for better understand how the new rule will impact each (e.g., pathway programmes, dual degrees, certificates, two-plus-two arrangements, intensive English programmes, undeclared majors)
• Communicating with current students and scholars, especially those approaching their program end dates

Stakeholder groups have already produced a number of explainers and background docs on the new rule, and this process of analysing the details of the rule and developing clear and effective guidance for students and advisors will no doubt continue for some time.

NAFSA, for example, has prepared a detailed set of on its duration of status page (login required). And a number of detailed background docs are already available, including the following:

• 
  ��
  For additional background, please see:

• “US to end ‘Duration of Status’ for F, J, and I visas and limit the time international students can study in the US”

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has just been released, and it gathers responses from 585 US colleges and universities over a period from 5 May through June 11. Collectively, the responding institutions host roughly half of the international students in the US.

The outlook for 2026/27

The survey highlights the following key trends for the coming academic year.

• Application volumes: 14% of responding institutions are reporting an increase in application volumes for 2026/27; 20% said that application volumes are roughly the same as the previous year; and 59% report a decrease in the number of applications.

• Projected enrolment: Nearly two in three respondents (63%) expect a decline in international student numbers for 2026/27; 26% predict stable enrolment year-over-year; and 11% forecast an increase in foreign enrolment.

Shifting demand from India looms as a major factor in the overall outlook for the year ahead. As IIE explains:

“At the country level, most reporting institutions indicate that international student applications either increased or remained stable across the majority of the 21 leading places of origin surveyed…The most pronounced decreases are reported for India, with only 39% of institutions indicating stable or increased application numbers. This is notable given that students from India made up nearly one-third (31%) of all international students in the United States in 2024/25.”

Contributing factors

Nearly all respondents (92%) cited visa processing issues (e.g., delays in processing or rising rejection rates) as the most significant factor affecting the enrolment outlook for this year. “Aligned with this concern,’ adds IIE, “64% of respondents noted an increase in questions and concerns from both current and prospective international students about the US political climate.”

The expanded travel ban and other travel restrictions were noted as an important factor by 80% of responding institutions. And the report notes as well that more than three in four respondents (77%) cited increased competition as a factor for 2026/27 with more students choosing to study in a destination other than the US.

“While this preliminary data suggests that enrollment numbers will decline in the 2026/27 academic year due to numerous factors,” concludes IIE, “it remains too early to determine the magnitude of potential declines.”

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“
• “What is happening to student mobility flows between the Global South and Global North?“
• “US visa processing centres in Africa to be reduced by more than half; only the latest barrier for African students“
• “Universities urged to focus on ‘factors they can control’ as policy settings depress international student enrolments in the Big Four“

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