• 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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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”

The post Report: US considering a $100,000 fee for Optional Practical Training appeared first on 91ɬ��Monitor - Market intelligence for international student recruitment.

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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The end of duration of status?

DHS, which includes United States Citizenship and Immigration Services and United States Immigration and Customs Enforcement, says it will publish an updated rule establishing a fixed time period for international student visas in July 2026.

from immigration law specialists Fragomen explains: “This month, DHS plans to issue final regulation that will end the longstanding practice of admitting foreign students (F nonimmigrants), exchange visitors (J nonimmigrants) and media representatives (I nonimmigrants) to the United States for the duration of their program – known as ‘duration of status’ – and switch to admitting individuals in these categories with a fixed expiration date, after which they will be required to file an extension with the immigration authorities in order to remain in the United States.”

For those who would like additional background on the forthcoming rule, we have written extensively about the pending changes to duration of status. Details of DHS’ proposed rule from August 2025 are .

This rule change has been anticipated all year and has the potential to introduce significant aspects of uncertainty and disruption for foreign students in the US. As such, we might expect that it will also be subject to legal challenge on publication.

Proposals pending for practical training

The newly published agenda for 2026 carries over an item from the prior agenda pertaining to .

Details of the planned reforms are now anticipated in February 2027. For the moment, DHS says only that, “The proposed rule will better align practical training to the goals and objectives of the program while providing more clarity to the public. The proposed rule 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.”

To the extent that those reforms affect the Optional Practical Training (OPT) programme, this could be another very consequential change in policy settings.

Of the 1,177,766 foreign students in the US in 2025, just over 294,000 (or about one in four) were in OPT. Participation in the programme was up 21% year-over-year from 2024 to 2025, continuing a multi-year programme of significant growth in programme participation.

Beyond its sheer scale, OPT is a critical aspect of the US offer to international students as it is the most widely used pathway to post-study work for foreign graduates. In a 2025 survey of current international students conducted by NAFSA and the Institute for Progress, 54% of respondents said they would not have enrolled at a US university had OPT not been available to them.

H-1B reforms

In another continuation of an item from the previous regulatory agenda, DHS say it intends to proceed with reforms to the H-1B work visa programme.

First published in , this amounts to a statement of intent to reform the programme “by revising eligibility for cap exemptions, providing greater scrutiny for employers that have violated program requirements, and increasing oversight over third party placements, among other provisions. These changes are intended to improve the integrity of the H-1B nonimmigrant program and better protect US workers’ wages and working conditions.”

There is no other detail in the agenda docs, except that the Department expects to publish its proposals for H-1B in August 2026.

For additional background, please see:

• “There are more international students in the US than ever in 2025, but commencements are declining“
• “US to end ‘Duration of Status’ for F, J, and I visas and limit the time international students can study in the US“
• “What international students need to know about study and work visas in the United States“

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It is no coincidence that the Key Five are all emerging countries in the Global South, where large proportions of students are open to emigrating, temporarily or permanently, because of limited local opportunities. This makes immigration officials tend to question whether study visa applicants are genuine students – i.e., interested in quality education, a high-skilled job, and remaining compliant with visa conditions – or individuals with little intent to study and great intent to migrate in any way they can. Unfortunately, many genuine students from the Global South are disadvantaged in their applications because of where they are from.

The impact of the visa rejection trend for students from emerging economies in Asia and Africa could be enormous across the global international education landscape – and beyond. Already, it is spurring fewer visa grants, reduced recruiting in high-risk markets, and more withdrawals from students eager to avoid a rejection on their student profile. Not surprisingly, commencements are trending down in leading study destinations, and this will pressure overall enrolments in the years ahead.

In this article, we will look at Key Five origin countries with regards to:

• Their importance to overall enrolments across the Big Four;
• Recent study visa rejection rates;
• Commencement trends (i.e., the volume of new students provided a study visa allowing them to enrol in a Big Four education institution).

Contribution to overall international student numbers

According to the most recent available enrolment data, Bangladesh, India, Nepal, Nigeria, and Pakistan compose anywhere from 30% to 40%+ of the entire international student body in Big Four destinations.

Visa rejection rates for the Key Five

Having looked at the huge presence of Key Five students in the total international student populations of the Big Four, we’ll turn to recent visa refusal trends (where official data are available).

Bangladesh: Nearly three-quarters (73%) of Bangladeshi applicants for US F-1 visas were turned away in 2025. Bangladeshi students have in recent years been very likely to receive a visa for Australia (about a 5% rejection rate in 2024/25), but in February 2026, more than half (51%) of offshore applicants from Bangladesh were refused.

India: Indian students, who represent either the #1 or #2 source market across the Big Four, are now quite likely to be refused a study visa in those destinations. Rejection rates were 61% in the US (2025), 80% in Canada (Q2 2025), and 60% in Australia (February 2026). While only 7.5% were denied a sponsored study visa in the UK in Q4 2025–Q1 2026, this this was up from less than 4% in winter 2024/25.

Nepal: More than 8 in 10 (81%) Nepali applicants were rejected for a US F-1 visa in 2025, and in February 2026, the Australian study visa rejection rate for Nepal soared to 65%. Interestingly, Nepali students were more likely to be approved for a UK sponsored study visa in winter 2025/26 than in winter 2024/25, bucking the general trend for emerging markets (see chart below).

Nigeria: Since December 2025, Nigerians have been included in an expanded travel ban announced by the US administration, along with dozens of other countries (mostly in Africa and Asia). In the UK, sponsored study rejections for Nigerian students used to be rare (less than 5%), but in winter 2025/26, 20% of Nigerian applicants were turned away. In Canada, between 70–80% were refused a study permit in in 2025.

Pakistan: More than 70% of Pakistanis were refused an F-1 visa in the US in 2026, and more than 6 in 10 offshore applicants from Pakistan were denied an Australian study visa in February 2026. Like Nigerians, Pakistani students applying for a sponsored study visa in the UK saw their rejection rate spike massively in winter 2025/26: increasing from 5.6% to 41% year-over-year.

These rejection rates for Key Five countries represent an absolutely huge number of potential students turned away.

What is happening to commencements?

Key Five commencements (new student entrants) are falling across the Big Four, with less than a handful of exceptions.
 
A striking example is F-1 visa issuances in the US in July/August of 2024 compared with July/August 2025. The percentages in the table below are based on our analysis of data from the US Department of State. It bears mentioning that in September of 2025 (not shown in the table), F-1 commencements fell further for Bangladesh (-69%), Nepal (-96%), Nigeria (-33%), and Pakistan (-9%) compared with September 2024.

In the UK, the following chart from HESA shows the dramatic drop-off in Indian (turquoise) and Nigerian (navy blue) commencements between 2023/24 and 2024/25: -13% and -33%, respectively. Over the span of two years (2022/23 to 2024/25), the declines were even more serious: -33% for India (126,580 to 94,955) and -132% for Nigeria (53,790 to 23,160).

In Canada, new student arrivals (from all nationalities) fell from 208,750 in 2024 to 115,120 in 2025. In January to April 2026 compared with the same period in 2025, arrivals were down -73% to about 200,000. There is no publicly available government information for specific markets, but the Times of India reports that between January and August 2025, Canada issued just 9,955 new study permits to Indian students.

In Australia, overall commencements fell by about -15% between 2024 and 2025, but this decline was concentrated in sectors other than higher education (the number of new international students in Australian universities edged up slightly in that time period). There was more of a mixed bag of commencement trends for the Key Five than in Canada, the UK, and US. Between 2024 and 2025, Indian and Pakistani commencements fell by -3.5% and -33%, respectively, while Nepal was up +33.5% and Bangladesh +33%.

The implications will stretch beyond international education

Our Key Five markets – Bangladesh, India, Nepal, Nigeria, and Pakistan – can be viewed as roughly representative of what is happening to mobility influences and flows between the Global South and Big Four destinations. They serve to show how immigration policies (and/or policy effects) in the Big Four are affecting demand from top non-EU markets. These policies, especially if they stretch on in time, could lead to:

• An intensification of existing challenges for the operations of hundreds of universities, colleges, and schools across the Big Four. Those institutions are often highly reliant on international student tuition amid declining domestic enrolments and/or public funding. Chinese commencements (which, for decades, were an important source of overall growth) are falling, and emerging markets in Asia and Africa have helped to mitigate the impact.

• Alternative destinations gaining a greater share of the world’s internationally mobile students (this is already happening – see From the Big Four to the Big Fourteen for background).



• A decline in the economic contribution of international education in the Big Four.



• A weakening of innovation and productivity in Big Four economies. India, in particular, contributes a large volume of STEM students and workers to Western nations.



• An erosion of the soft power of the Big Four in the Global South.

Methodological note

Data analyses are based on statistics from:

• The Australian
• (IRCC)
• The UK’s (HESA)
• The in the US

For additional information, please see:

• “UK: International student numbers fall for second year, especially in postgraduate programmes“
• “UK: Sponsored study visa issuances down, rejection rates up, and more“
• “There are more international students in the US than ever in 2025, but commencements are declining“
• “Visa rejections climb in the US for international students from key markets including India“
• “New international student permit approvals for Canada fell below COVID levels in 2025“
• “Australia: Multiple data indicators signal further declines ahead for international student numbers“
• “Australia: Latest enrolment data challenges the government’s assertion of stability for international education this year“

The post What is happening to student mobility flows between the Global South and Global North?�� appeared first on 91ɬ��Monitor - Market intelligence for international student recruitment.

Little by little, the wall gets higher

The movement to restrict African nationals from coming to the US began in the summer of 2025, when the administration stopped processing the visas of students (and other nationals) from several countries including Chad, Congo, Equatorial Guinea, Eritrea, Libya, Somalia, and Sudan. This list was quickly expanded to include Angola, Burkina Faso, Cameroon, Côte d’Ivoire, Djibouti, Egypt, Ethiopia, Gabon, the Gambia, Liberia, Malawi, Nigeria, Niger, Senegal, South Sudan, Tanzania, Uganda, and Zimbabwe.

In bluntest terms: Of the 54 countries in Africa, almost half made the travel ban list in the summer of 2025. Currently, African countries account for the lion’s share of all 39 countries on that list.

In January 2026, the government began targeting African students already in the US. Immigration officers were directed to pause visa processing for students from travel-ban countries applying for Optional Practical Training (OPT) and extensions, the H-1B programme, or the work component attached to J-1 visas. That same month, the pause applied to Green Card applicants from 23 African countries, many of which were on the travel ban list.

Now, in June 2026, the US State Department is from 50 consular posts to 20 designated regional hubs. This means all African students will have to travel to one of those 20 hubs to apply for a US study visa and sit for an interview. Some prospective applicants live hundreds of kilometres away from a hub. Reaching a hub may now necessitate flights and staying over in more than one city.

The impact

Policy after policy is now making it nearly impossible for many African students to study in the US. Through visa bans and high rejection rates; immigration restrictions; and now the reduction of visa processing offices, the barriers are mounting for African students hoping to study in the United States.

African markets have been the fastest growing sources of students for US universities in recent years. For example, between 2023/24 and 2024/25, according to , these were the biggest growth stories, including top 20 markets of Nigeria (#8) and Ghana (#14):

• Cameroon: +20.5% to 1,180
• Ethiopia: +10.5 to 3,400
• Tanzania: +11% to 1,140
• Uganda: +15% to 1,500
• Zimbabwe: +42% to 2,700
• Ghana: +36.5% to 12,830
• Nigeria: +9% to 21,850

Overall, African enrolments in US higher education institutions grew by +15% in 2024/25 compared with +5% for Asia, +3% for Europe, and +2.5% for Latin America and the Caribbean.

For additional background, please see:

• “US extends travel ban, Nigeria now included on restricted list“
• “US: Student visa issuances fell by -36% in summer 2025; OPT uncertainty among factors affecting international student demand”

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