Department of Homeland Security Proposes Fee for OPT Recommendations from Certified Schools
The Department of Homeland Security proposed rules on Wednesday to charge schools certified under the Student and Exchange Visitor Program a fee for OPT recommendations: an initial fee of $70,000 for each F-1 student, followed by $30,000 for any subsequent recommendations, with a 24-month extension for STEM fields included in the subsequent filings. The rules are not yet in effect.
The fee is incurred before the school issues the recommendation. If the school does not pay, the U.S. Citizenship and Immigration Services will not approve the employment authorization. The fee is not tied to a specific employer and is paid to the U.S. Treasury. Both pre-completion OPT during studies and post-completion OPT after graduation are applicable. The current I-765 application fee remains $470 for online applications and $520 for paper applications, and there was previously no fee for school recommendations.
Under current rules, F-1 students can have a maximum of 12 months of OPT for each degree level, with an additional 24-month extension for STEM fields, totaling a maximum of 36 months. If both the initial and extension are fully utilized, the cost to the school for a single student would be $100,000. A department spokesperson referred to OPT as a "backdoor" to the labor market, stating that the fee aims to reduce low-cost labor, facilitate competition for U.S. citizens, and require foreign students to demonstrate their value to employers.
The public comment period is from October 8 to November 9, with an additional 60-day comment period for paperwork reduction provisions. If finalized, the rules will take effect 60 days after publication, applying only to new recommendations and not retroactively to those already authorized. Higher education associations and business groups may sue, which could delay implementation. The department indicated that schools could pass the costs onto students or employers.
This is the second six-figure fee imposed by the same administration on high-skilled labor. A presidential order in September 2025 added a $100,000 fee for certain H-1B entrants, which was extended for another year in September 2026. OPT was originally a 12 to 36-month position for many graduates while waiting for the H-1B lottery, and the new fee raises the barrier for this position to the schools.
The buyers are the schools that must pay the Treasury for each recommendation, while the sellers are the immigration system that issues employment authorizations. This event is driven by the proposed rules, not by enacted bills. Funds will flow from tuition, employer reimbursements, or out-of-pocket payments by students to the Treasury. The beneficiaries are what the department calls domestic job seekers, while the burden falls on schools that rely on OPT commitments for enrollment, employers dependent on recent international graduates, and F-1 students who consider graduate work visas as part of their path to stay in the U.S.
The $70,000 applies to the first 12 months, and the additional $30,000 applies to subsequent recommendations. Existing applications will still follow the old fee structure until the comment period ends.
Source: Public Information
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Trump's first term saw attempts to modify OPT. In 2020, the Department of Homeland Security drafted texts to restrict work visas for international students and online course statuses, which were blocked by courts and the change of administration. The presidential order in September 2025 shifted to fees: an additional $100,000 for certain new H-1B entrants, extended for another year in September 2026. This time, the duration of OPT remains unchanged, but the price for school recommendations has been raised, effectively turning an uncut program into an unaffordable one.
The capital path stops at the school, not directly at the student visa fees. Schools certified under the Student and Exchange Visitor Program must first pay $70,000 to make a recommendation, after which the U.S. Citizenship and Immigration Services will issue work cards, with the money going to the Treasury. Schools can pass the costs onto students or employers, leading to tuition premiums, hiring subsidies, and the option to forgo OPT. India and China are the largest sources of F-1 students, and the STEM extension is the main pathway for these students to remain in the workforce. Employers relying on recent international graduates to fill software and lab positions will have to consider whether schools are willing to front this $100,000 fee in addition to the six-figure costs of H-1B visas.
This can be compared to the $100,000 entry fee for H-1B in 2025, as well as Canada and the UK using study permits and work visa durations instead of a single six-figure recommendation fee to filter candidates. The position of U.S. higher education is in a phase of quantity control: international student tuition remains a cash flow for both public and private schools, and work visa commitments are part of enrollment pitches. Once the fees are enacted, the promised duration for enrollment remains, but the promised price is gone.
This is a regulatory change. The mechanism is that OPT does not have a separate statutory quota; school recommendations combined with employment authorizations constitute supply. By raising the recommendation price to $70,000, supply is no longer determined by the number of graduates but by whether schools can pass the costs on. The Treasury collects an access fee, while employers lose the low marginal cost of a 12 to 36-month trial period. The comment period and potential lawsuits can delay implementation, but they cannot change this pricing logic.
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Channels that cannot be eliminated will be transformed into unaffordable channels.
Costs are written under the school's name, and the bill will find the student.
For programs without quotas, price is the quota.