• 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” 

The post US government warns universities to limit their authorisation of Curricular Practical Training work placements appeared first on 91ɬ��Monitor - Market intelligence for international student recruitment.

Our co-hosts are then joined by special guests Gordon Scott, the CEO of Successful Graduate, and Sheenu Kathuria, CEO of EduNation Consultants. The group gets into a great discussion around how the employability conversation is unfolding with students and families now, and where expectations and reality around graduate outcomes diverge.

You can listen right now in the player below, and we encourage you to subscribe via your favourite podcast app in order to receive future episodes automatically.

For additional background, please see:

• “The questions families are actually asking: Inside the student advising conversation in 2026“
• “91ɬ��Podcast: ‘Good, steady, and disciplined’: New Zealand’s plan for sustainable international enrolment growth“

The post 91ɬ��Podcast: Beyond the brochure: What employability really looks like for students appeared first on 91ɬ��Monitor - Market intelligence for international student recruitment.

Today the session starts somewhere else. The student still arrives with a list. But the first question now usually comes from the parent, and it is rarely about a university at all. Will this degree pay back the years and the money? Will it still be relevant when my child graduates? Will artificial intelligence make it obsolete before the loan is repaid?

I have heard versions of these three questions in counselling rooms in Chandigarh, Manila, Lagos, and Bogota. They are asked quietly, sometimes almost apologetically, but they are serious questions, and they shape family decisions worth billions of dollars every year. They have also quietly changed what good student advising looks like.

Why the counselling room matters

It is easy to underestimate how much of international education still runs through a single conversation between a family and an adviser. According to the American International Recruitment Council, 44% of international students rely on recruitment agents to help them decide what and where to study. And the reason they are in that room has changed too. Career development is now the number one motivator for studying abroad, cited by 67% of students in IDP’s Emerging Futures research. Students are not just buying an experience any more. They are buying a working future.

That places advisers at a point of real leverage. The counselling conversation is where family hopes meet market reality, often for the first time. When expectations shift, advisers feel it before institutions do, and long before policy makers do. Which is why what we are hearing in those rooms now deserves attention.

From prestige to proof

When we ran the fieldwork for the this year, covering 4,812 agents, students, institution leaders and employers across 25 countries, one pattern came through more strongly than any other: families have stopped asking for prestige and started asking for proof.

In South Asia, 89% of recruitment agents told us their top request from institutions is now skill-mapped programme documentation, not brochures. In North America, agents named post-study visa clarity and programme-level outcome data as the top two concerns students bring to them, at 78% and 71%. Across regions, parents increasingly ask employment questions before they ask admission questions.

The shift makes sense once you see the counselling room from the family’s side. A ranking describes an institution. But a family is not buying an institution. They are buying one specific degree, and they want to know what happens to the people who finish it. Institution-level averages do not answer that. Programme-level outcomes do, and families have worked this out faster than much of the sector has.

The safety net that isn’t there

For a long time, advising had a comfortable answer to the anxiety behind these questions: choose a good university, and if the job market changes, you can always reskill later. Our research suggests that answer no longer holds.

Across OECD countries, only 8% of adults take part in formal, accredited learning in a given year, and the open online courses that were supposed to close the gap complete at a median rate of 12.6%. Meanwhile, 53% of the technical skills a graduate learns in year one are judged obsolete within three years. Skills are going out of date roughly six times faster than the system replaces them. Reskilling after work exists, but as a safety net for an entire generation, it is thin. Families who press on curriculum quality before enrolment, rather than trusting the system to patch things later, are being rational.

What is more encouraging is what employers told us they actually hire on. In our survey, 73% of employers said they hire recent international graduates primarily for durable skills, things like communication, judgment, ethical behaviour, and the ability to work across cultures, rather than for a specific technical stack. Technical tools change. These capabilities compound. For an adviser, that is a genuinely useful message to carry into a conversation with an anxious parent: the degree that protects your child is not the one with the most fashionable specialisation, it is the one that builds the skills that survive the tools.

Will AI make it obsolete?

We put that exact fear under a microscope in this year’s Barometer. Comparing internationally-mobile graduates against domestically-educated peers in the same fields, employers placed 71% of the internationally-mobile group in AI-augmented roles, work where AI expands what one person can do rather than replacing them, against 54% for domestic graduates. Only 6% of the internationally-mobile group sat in roles at material AI-displacement risk. For domestic graduates in the same fields, that figure was 14%, over twice as high. PwC’s analysis of nearly a billion job postings found the same pattern at market scale: workers with AI skills now command a 56% wage premium globally, more than double what it was a year earlier.

None of this makes the advantage automatic. It is built on the durable skills, the cross-cultural fluency and the sequenced curriculum design that produced it in the first place. But it does mean an adviser can answer a parent’s hardest question with a number instead of a reassurance.

What good advising looks like now

None of this requires advisers to become labour economists. In our work with counselling teams, the practices that are working are simple ones.

The first is to ask institutions for programme-level employment data, in writing, rather than settling for institution-level claims. Institutions that have this data increasingly share it, and the act of asking signals what families now expect.

The second is to talk to parents about durable skills directly. Parents understand instinctively that communication, adaptability and integrity matter at work. Naming them as the core of a degree’s value, with evidence, answers the AI question far better than reassurance does.

The third is to screen recommended programmes for work-integrated learning and international cohorts. Internships, placements and genuinely mixed classrooms are where durable skills form, and they show up later in employment outcomes. Arizona State University’s National Work-Integrated Learning Accelerator now generates 1.8 million experiential-learning hours per student cohort. In the Netherlands, international graduates who complete structured cross-cultural programmes actually out-earn their domestic peers, 48% of them clear €55,000 a year against 44% of domestic graduates in the same bracket. Programmes built this way are not hard to find once an adviser starts asking for them by name.

The fourth is simply to keep the post-study visa picture current for every destination, because in several markets it has become the first question, not the last.

Advising as trust infrastructure

There is one more finding from our study worth sitting with. Among UK-bound students we surveyed, 64% said they would still choose the UK despite recent visa changes, provided programme-level employment data was transparent. Read that carefully: even in a market facing policy headwinds, transparency holds demand. Families are not asking for perfect conditions. They are asking to see the evidence and decide for themselves.

That, to me, is the real story of how counselling is changing. The adviser’s role is shifting from gatekeeper of options to interpreter of evidence. It is less glamorous than selling dreams, and considerably more valuable. Students get decisions they can defend at the kitchen table. Institutions that publish honest outcomes get rewarded for it. And the sector gets something it badly needs, which is trust built one family conversation at a time.

The questions parents ask in counselling rooms are harder than they were five years ago. That is not a problem to be managed. It is the clearest sign we have that families are taking the decision seriously, and the sector should answer them in kind.

– Dr Priya Ranganathan is research director at MSM Unify, where she leads the company’s global research programme, including the annual MSM Unify Global Skills Barometer, a study of agents, students, institution leaders and employers across 25 countries. MSM Unify is a global education platform supporting institutions, students, and channel partners across international education markets. MSM Unify helps institutions strengthen student recruitment, enrolment management, and education delivery through technology, services, and global market expertise.

For additional background, please see:

• Readers who want to explore contemporary counselling issues more closely should consider , newly released by 91ɬ��Academy in partnership with Successful Graduate
• “Global agent survey reveals international students’ top concerns are visa uncertainty and affordability“
• “What students want: The top decision factors for study abroad“

The post The questions families are actually asking: Inside the student advising conversation in 2026 appeared first on 91ɬ��Monitor - Market intelligence for international student recruitment.

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“

The post Visa delays and policy uncertainty projected to reduce foreign enrolment in the US by more than 100,000 students this fall appeared first on 91ɬ��Monitor - Market intelligence for international student recruitment.

The latest figures from the Korean Immigration Service put the number of international students in South Korea at 314,400 as of February 2026. More than a third (115,140) are from Vietnam; another quarter (78,530) come from China. The vast majority (76% or 238,905 students) are enrolled in higher education institutions, with the balance (roughly 75,500) in Korean-language studies.

With that growth trajectory firmly established, important changes are taking shape in Korea, including greater attention to the sustainability and quality of education and to the international student experience.

reported earlier this year, for example: “South Korea’s universities are entering a new phase of internationalisation. In a recent shift, several institutions have moved beyond offering English-medium tracks and have begun establishing entire departments and majors exclusively for international students.

“For decades, internationalisation has been framed through integration. International students were expected to enter existing programmes, adapt to institutional norms and participate within shared academic spaces. Even when English-medium instruction expanded, it was presented as a mechanism for inclusion, a way of lowering barriers while maintaining institutional coherence.

“The current shift departs from this logic. Programmes designed exclusively for international students introduce structured differentiation within the university itself. They are not merely parallel in language or support provision. They are parallel in design. Admissions criteria, curricular content, pedagogical expectations and career pathways may all diverge.”

adds that, even as Korean institutions are being encouraged to continue to expand foreign enrolments, the country’s Ministry of Education is already moving to introduce new quality controls: “In the near term, it plans to impose sanctions on universities that fail to screen international students properly. Over the longer term, it aims to revamp its internationalisation certification program to better reflect universities’ actual capabilities.”

A particular area of concern is the Korean-language proficiency of visiting students and how that relates to student retention and success. The Ministry of Education recommends at least a Level 3 on the Test of Proficiency in Korean (TOPIK) for foreign students seeking admission to a Korean university. The Korean Council for University Education has reported, however, that just over half of the international students currently in Korea fall below that language proficiency benchmark. “The issue is structural,” explains a report in . “Admission decisions are largely left to institutional discretion, and universities face no direct penalties for enrolling students who do not meet the ministry’s guidelines.”

At the same time, there are growing reports of additional measures that institutions are taking to assist visiting students in integrating more effectively into Korean life, including mentoring or peer supports, socio-cultural programmes, or local outreach or volunteer opportunities.

“Korea has already proven that it is good at attracting international students,” Rezia Usman, regional director of the office of international affairs at Woosong University, said to Korea JoongAng Daily. “The challenge now is making sure those students feel they are truly learning the [local] language and culture while universities also help them build their careers in Korea.”

Plans to stay

Those challenges around integration of foreign students – and the need for expanded language and social supports – sit in contrast to the findings of a recent study from the Korean Educational Development Institute. It found that, as of 2023, nearly two-thirds (63%) of international students in Korea said that they wanted to stay in the country after graduation. That was up from 2017, at which point 41% indicated they wanted to stay.

Of those planning to stay on, 35% were hoping to find a job in Korea, while another 27% wanted to continue their studies.

The Institute also found that nearly half (42%) of the graduates of two- or three-year colleges in Korea earned at least 3 million won per month (US$2,110) as of 2023 (up from 15% who earned at that level as of 2021). Roughly a third of bachelor’s degree holders and 44% of master’s programme graduates also earned above that threshold as of 2023.

A separate study from the Ministry of Data and Statistics found that as of May 2025 roughly 56,000 foreign students in Korea were also working during their studies. Nearly all (83%) worked in part-time jobs in the retail, accommodation, or food services sectors, with most earning less than 2 million won per month (US$1,406).

A related report in adds: “International students in Korea may take part-time jobs if they meet requirements including academic performance and Korean-language proficiency. The permitted working hours and types of employment vary depending on their degree program, language ability, and immigration status … Because their visas require them to remain enrolled and prioritise their studies, many are employed on temporary or daily contracts rather than in regular full-time positions.”

For additional background, please see:

• “South Korea hits its 300,000 student target two years ahead of schedule“
• “Annual student city ranking underlines continued ascent of Asian destinations“

The post After years of growth, Korea faces the challenge of better integrating and retaining international students appeared first on 91ɬ��Monitor - Market intelligence for international student recruitment.

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.

The public files are in many respects an under-appreciated resource, because they provide detailed guidance about the rules and compliance requirements for Canada’s various immigration streams. They also provide a window into how, over time, that guidance can be expanded, clarified, or otherwise changed.

The larger context here is that many students gather information about compliance or the fine points of their visa status from peers, through online message boards, and from other unofficial sources. Many, too, file their own applications for visas or renewals without assistance from an authorised advisor or lawyer – and they may or may not be aware of the latest official guidance.

A number of changes have been published in recent weeks to the reference files for study permit and post-graduate work permit (PGWP) compliance. Not all of these are rule changes. Rather, many take the form of useful clarifications of established policy or practice. That said, keeping track of those changes can be tricky as they may not be publicly announced or otherwise highlighted in the published files.

In broad terms, the revisions made in the second half of June point to greater scrutiny of the enrolment status and academic progress of continuing students, students transferring between programmes and institutions, and students’ absence or leave from studies. They also introduce important updates to PGWP eligibility, and they mark the end of an exception for temporary residents to pursue studies in Canada without a study permit.

Actively pursuing studies

The current version (as of 18 June 2026) of the IRCC file “” expands on the department’s expectations for the active pursuit of studies and academic progression with additional detail on when the programme of studies is considered to be completed.

Specifically, it stipulates that:

“Studies are considered officially completed on the date the DLI first notifies the student by any of the following:

• Completion letter
• Transcript
• Degree or diploma

The date stated on the document will be considered the date of notification unless the applicant and/or DLI can provide proof of a different date.”

The significance of that mechanism is underscored by a related note in the study permit guidance, which specifies that the student’s study permit “will become invalid … 90 days after the day the study permit holder completed their studies.”

Changing DLIs or programmes of study

The include considerable expansion of the rules around transferring between institutions.

This guidance is based on a rule change, effective 8 November 2024, which stipulates that “study permit holders in Canada, whose permit names a DLI [Designated Learning Institution], must apply for a new study permit if they wish to change designated learning institutions (DLIs).”

The updated file expands on this point by specifying that “study permit holders must adhere to the condition that they remain enrolled at the DLI named on their study permit until they complete their studies … their study permit becomes invalid on the day that they are no longer enrolled at the DLI named on their study permit, other than as a result of completing their studies.”

“Therefore, if a student whose study permit names a DLI has changed DLIs without applying for a new study permit, their previous study permit is rendered invalid and the student is considered to be studying without authorization at the new DLI.”

The updated guidance also addresses the scenario where a student may have a study permit that does not specify a DLI: “If a post-secondary student holds a study permit issued prior to November 8, 2024,that does not name a DLI, they should apply for a new study permit when changing DLIs. Once that study permit with no DLI is expired, they must apply for a new study permit which will be issued with the name of the DLI they are attending.”

The bottom line is that students cannot change institutions before they obtain a new study permit that specifies the new DLI.

The exception to this pertains to students who transfer to a different programme of study within the same DLI: “Students engaging in post-secondary studies in Canada are authorized to change programs of study within the same DLI at the same level of study, provided they are not limited from doing so by conditions imposed on their study permit.”

Finally, the expanded guidance in this area also provides some clear provisions for secondary students transitioning to post-secondary education:

“Students must apply for a new study permit with the DLI’s name on it when they transition to post-secondary studies to avoid any non-compliance issues.”

And:

“If a student is attending a secondary school while on a visitor record, they must wait for their study permit application to be approved before beginning studies at the post-secondary level.”

Leave from studies

remains consistent from past versions in that, “Students may be required or may wish to take leave from their studies while in Canada. For the purpose of assessing if a student is actively pursuing their studies, any leave taken from a program of studies in Canada should not exceed 150 days from the date the leave commenced and must be authorized by their DLI.”

However, the 18 June updates expand on multiple leave periods and work rights during a leave from studies.

The point regarding multiple leave periods is in keeping with an overall pattern towards greater scrutiny of student progress: “In cases where a student has taken multiple periods of authorized leave in Canada during their program of study, the officer should consider the student’s reasons for the various periods of leave. If the multiple periods of leave do not appear to support the expectation that the student is making reasonable progress toward the completion of their course or program of study in the time allotted by the course or program of study, the officer may determine that the study permit holder has not fulfilled the condition to actively pursue their course or program of study.”

And on the question of working during a leave from studies, the updated document sets out plainly that, “If a study permit holder is not attending class full time, they are not eligible to work as per the condition listed on their study permit … During any leave from studies, including DLI closures, a study permit holder cannot work on or off campus.”

PGWP and non-credit programmes

IRCC also updated its guidance for on 24 June 2026. The notable change here occurs in the section “Who’s not eligible for a PGWP” which has been changed to specify that students are not eligible if they have “completed a non-credit program of study (except for a flight school program).”

The significance of such updates is underscored by the high-profile case of a large number of PGWP application rejections this month for graduates from the Canadian Institute of Osteopathic Therapy (CIOT) in Calgary. CIOT delivers programmes in partnership with , and students in such public-private partnerships (P3) are no longer eligible for PGWPs following a rule change that came into effect on 15 May 2024.

However, many of the CIOT students who have had their PGWP applications refused began their studies prior to that May 2024 effective date, and therefore should be grandfathered under the previous policy that allowed students in P3 programmes to be eligible for post-study work.

, an independent news outlet, reports that, “The students immediately inquired about this with [IRCC], which said the mass rejections were due to recent policy changes, including that non-credit courses were no longer eligible for work permits …. This modification was made on June 24, years after the students initially started their programs and 18 to 21 months after they submitted their work permit applications.”

In a written response to Livewire Calgary, IRCC explained that “There have been no changes to the eligibility criteria. We updated our PGWP webpage in June 2026 to clarify the existing eligibility requirements related to non-credit programs of study.”

The inference from that reporting is that (i) the policy around non-credit study may have been clear within IRCC but may not have been commonly understood otherwise; (ii) IRCC appears to have determined that there was some ambiguity in this area, thus the 24 June update; and (iii) because this does not represent, in the apparent view of IRCC, a rule change (but rather a clarification), students may not be automatically grandfathered.

91ɬ��Monitor understands that many of the affected students are appealing their PGWP refusals and that the published guidance in this area may be further tested as a result.

Study for work permit holders

Finally, IRCC has also closed out that allowed some work permit holders to study in Canada without a study permit.

This policy had been in place from 27 June 2023, and it officially expired on 27 June 2026.

For additional background, please see:

• “OECD: International students may be underinformed about job prospects in top destinations“
• “New data provides early signals that Canada’s popularity as a study destination is on the rise“
• “New international student permit approvals for Canada fell below COVID levels in 2025“
• “Canada’s foreign enrolment has fallen by nearly 300,000 students over the last two years“

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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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