Pre-Completion vs Post-Completion OPT: How Each Works, What It Costs Your OPT Time, and the Proposed Fee Math
Pre-completion OPT spends the same 12 months you need after graduation, and a pending DHS proposal would price every OPT recommendation separately.
Part of our guide to Day 1 CPT.
Pre-completion OPT is F-1 work authorization you use before your program ends; post-completion OPT is the same benefit used after you finish. Both draw from one 12-month allowance per degree level, so every full-time month of pre-completion OPT (or every two part-time months) is a month you lose after graduation. CPT does not draw down those months. And under a DHS proposal published 2026-10-08 that is not law, each separate OPT recommendation would carry its own fee, so splitting OPT would cost far more than using it once.
If you have an internship offer for next summer and your international office has mentioned CPT or pre-completion OPT, here is the trade-off in months and in proposed dollars.
Status as of October 14, 2026. OPT rules (12 months per degree level, 90-day unemployment limit, 150 days with STEM OPT) are in effect and unchanged. The OPT fees NPRM ($70,000 initial / $30,000 each subsequent recommendation) is proposed: published 2026-10-08, comments close 2026-11-09. SEVP's CPT broadcasts BCM 2608-01 and 2608-02 are in effect as guidance and challenged in court (hearing 2026-11-06). The Duration-of-Status rule is blocked by a federal court order of 2026-09-14, so the 60-day F-1 grace period still applies.
How pre-completion OPT works
Pre-completion OPT is authorized under the F-1 regulations for students who have been in valid status for at least one full academic year. It is filed on Form I-765 under category (c)(3)(A), after your DSO enters a recommendation in SEVIS. The USCIS I-765 page is the source of truth for the current edition, filing fee and filing address.
The rules that shape how you can use it:
- While school is in session, pre-completion OPT is part-time only, at no more than 20 hours per week.
- During your annual vacation (usually summer), it can be full-time.
- After you finish all coursework in a bachelor's, master's or doctoral program that still requires a thesis or dissertation, it can be full-time.
- The work must be directly related to your major, just like post-completion OPT.
- You cannot start work until USCIS approves the EAD and the start date on the card arrives. A DSO recommendation is not permission to work.
What pre-completion OPT costs your clock
This is the part most students miss. The regulations deduct full-time pre-completion OPT one-for-one, and part-time pre-completion OPT at half the full-time rate.
| Pre-completion OPT you use | Deducted from your 12 months | Post-completion OPT left |
|---|---|---|
| None | 0 months | 12 months |
| 3 months full-time (one summer) | 3 months | 9 months |
| 6 months part-time (one semester plus) | 3 months | 9 months |
| 4 months part-time + 3 months full-time | 5 months | 7 months |
| 12 months full-time | 12 months | 0 months (no post-completion OPT, so no STEM OPT to extend) |
As of October 2026. Your EAD and SEVIS record control.
A summer of full-time pre-completion OPT, the most common case, means you graduate with nine months of post-completion OPT instead of twelve. For a STEM student that also shortens the window to land a STEM-OPT-eligible employer, because the 24-month extension is requested from post-completion OPT.
How post-completion OPT works
Post-completion OPT is filed on Form I-765 under category (c)(3)(B). The current filing window opens 90 days before your program end date and closes 60 days after it, and USCIS must receive the application within 30 days of your DSO's recommendation. The USCIS OPT overview explains each window.
Once approved:
- You must work at least 20 hours per week in a job directly related to your field for the time to count as employment.
- The 90-day unemployment limit applies, rising to 150 days in aggregate if you get the 24-month STEM extension (SEVP BCM 2101-01). Our guide to staying ahead of the 90-day unemployment clock covers how the days are counted.
- When it ends, you have the 60-day F-1 grace period. That is still the rule because the Duration-of-Status rule was blocked on 2026-09-14. Some school web pages written before that date still describe a 30-day grace period; confirm with your DSO.
One timing caution: avoid travelling outside the US while a post-completion OPT I-765 is pending. Leaving after your program ends without an approved EAD can complicate re-entry, so talk to your DSO before you book anything.
Pre-completion vs post-completion OPT side by side
| Pre-completion OPT | Post-completion OPT | |
|---|---|---|
| I-765 category | (c)(3)(A) | (c)(3)(B) |
| When you can use it | After one full academic year in status, before program end | After program end date |
| Hours | Part-time (max 20/week) in session; full-time during breaks or after coursework | At least 20/week to count as employed |
| Draws from your 12 months | Yes; part-time at half rate | Yes, month for month |
| Unemployment limit | Not the 90-day post-completion counter | 90 days (150 aggregate with STEM OPT) |
| Leads to STEM OPT | No, not directly | Yes, if your degree and employer qualify |
| Covered by the proposed OPT fee | Yes (proposed) | Yes (proposed) |
For the wider picture of all three work authorizations, our OPT vs STEM OPT vs CPT comparison for 2026 puts them in one table.
The proposed OPT fee math
On 2026-10-08, DHS/ICE published the NPRM "Optional Practical Training Fees" in the Federal Register. It is proposed. Nothing changes today. Comments close 2026-11-09.
What the proposed text says:
- $70,000 before a student's initial OPT recommendation.
- $30,000 for each subsequent OPT recommendation. STEM OPT counts as subsequent.
- It covers any type of OPT: pre-completion, post-completion and STEM OPT. CPT is out of scope.
- The SEVP-certified school pays before the DSO recommends. DHS says schools "may pass the financial obligation" to F-1 students, all students, or employers.
- It would apply only to DSO recommendations dated 60 or more days after a final rule. Already-authorized OPT would not be affected (an inference from the rule's prospective transition clause).
The NPRM's own worked examples: $70,000 for pre-completion OPT plus $30,000 for post-completion OPT, and $100,000 total for initial OPT plus STEM OPT.
| Your OPT sequence (if the proposal became final unchanged) | Recommendations | Proposed fee per recommendation |
|---|---|---|
| Post-completion OPT only | 1 | $70,000 (initial) |
| Post-completion OPT, then STEM OPT | 2 | $70,000, then $30,000 ($100,000 total per the NPRM) |
| Pre-completion OPT, then post-completion OPT | 2 | $70,000, then $30,000 |
| Pre-completion, post-completion, then STEM OPT | 3 | $70,000, then $30,000, then another $30,000 |
Proposed amounts as of October 2026. Not in effect.
The structural point: today, splitting your OPT costs you time. Under the proposal it would also add a separately priced recommendation. Nobody yet knows how individual schools would respond. Our explainer on who would pay the proposed $70,000 OPT fee goes deeper on the school-as-payer mechanism.
| Topic | Rule today (in effect) | Under the proposal (proposed) | What to do differently now |
|---|---|---|---|
| Cost of an OPT recommendation | No DHS OPT fee; USCIS I-765 fee only | $70,000 initial, $30,000 each subsequent, paid by the school | Ask your international office whether it has published a position |
| Splitting pre- and post-completion OPT | Costs months off your 12 | Costs months plus a separate $30,000 recommendation | Factor both costs into any pre-completion decision with your DSO |
| CPT | Governed by school authorization and SEVP guidance | Not covered by the fee | Ask your DSO how BCM 2608-01/02 affects your program |
| Timing | Current filing windows apply | Only recommendations 60+ days after a final rule | Do not assume the fee applies to a recommendation dated today |
OPT or CPT for an in-program internship
If you are deciding between OPT or CPT for work during your degree, the trade-offs moved twice this autumn.
CPT does not spend your OPT months. Part-time CPT never affects OPT; 12 months or more of full-time CPT eliminates OPT eligibility at that degree level. CPT is also outside the proposed OPT fee.
But CPT itself has narrowed. SEVP's BCM 2608-01 (2026-08-12) says DSOs may authorize CPT only when its absence would make the degree impossible and the work is required for all students in that degree. The Q&A in BCM 2608-02 (2026-08-24) adds that elective-course CPT fails the "integral and required" test. Both are in effect as guidance and challenged in Association of American Universities v. DHS, with a hearing on 2026-11-06 and no ruling yet.
The Harvard Crimson reported on 2026-10-06 that five Harvard schools no longer authorize CPT, and that MIT, Penn and Wellesley paused CPT applications. Your school's policy may differ; confirm it with your DSO.
The honest picture: CPT protects your OPT clock and sits outside the fee proposal, but it may be unavailable at your school right now. Pre-completion OPT may be available where CPT is not, at the price of post-graduation months. For internship structures specifically, see how internships and co-ops affect your OPT, and if you are weighing a Day 1 CPT program, read Day 1 CPT vs OPT first.
A planning timeline for in-program work
- Six months before the work starts: Ask your international office which routes it currently authorizes for your program.
- Five months out: Count your remaining OPT months with the table above, and ask your DSO what a given pre-completion plan would leave.
- Four months out: Confirm the job is directly related to your major and fits that term's hour limits.
- As your DSO advises: The DSO enters the recommendation in SEVIS, and USCIS must receive the I-765 within 30 days of that date.
- While the I-765 is pending: Track it on the USCIS processing times page and do not start work early.
- Before graduation: Plan your post-completion filing window around the months left, and watch for a final OPT fee rule.
Common mistakes
- Treating pre-completion OPT as free time. It comes out of the same 12 months as post-completion OPT. A summer of full-time work is three months you will not have after graduation.
- Starting on the DSO recommendation. You need an approved EAD and its start date, not just the SEVIS entry.
- Writing "OPT now costs $70,000." It does not. The fee is proposed, the school is the legal payer, and it would apply only after a final rule.
- Assuming CPT is either safe or banned. The SEVP broadcasts are guidance in force, under challenge. Your school's practice decides your options.
Frequently asked questions
Does pre-completion OPT reduce my post-completion OPT?
Yes. You get 12 months of OPT per degree level, and pre-completion and post-completion OPT draw from the same pool. Full-time pre-completion OPT is deducted month for month, and part-time pre-completion OPT is deducted at half the full-time rate. Whatever you use before graduation is gone from the post-completion period.
Would the proposed $70,000 OPT fee apply to pre-completion OPT?
Under the DHS proposal published on October 8, 2026, yes. The NPRM covers any type of OPT, so a pre-completion recommendation would be your initial recommendation at $70,000 and a later post-completion recommendation would cost $30,000. It is only a proposal, the school is the legal payer, and it would apply only to DSO recommendations dated 60 or more days after a final rule.
Is OPT or CPT better for an internship during my degree?
They are different authorizations with different costs to your future time. CPT does not draw down your OPT months, and the OPT fee proposal does not cover CPT, but SEVP guidance issued in August 2026 has narrowed when schools can authorize CPT and that guidance is being challenged in court. Which one fits your internship is a question for your DSO, who controls both recommendations.
Does the 90-day unemployment limit apply to pre-completion OPT?
The 90-day unemployment limit is a post-completion OPT rule, and it rises to 150 days in aggregate if you receive the 24-month STEM extension. Pre-completion OPT is tied to your enrollment rather than an unemployment counter. Your DSO can confirm how your own SEVIS record is tracked.
Can I still get STEM OPT if I used pre-completion OPT?
STEM OPT is an extension of a period of post-completion OPT, so you need post-completion OPT time left to extend from. Using part of your 12 months before graduation shortens post-completion OPT, and using all 12 months would leave no post-completion period at that degree level. Confirm the exact effect on your record with your DSO before you file.
Sources
- USCIS, Form I-765 (current edition, fee and filing address)
- USCIS, Optional Practical Training for F-1 students
- Federal Register, Optional Practical Training Fees NPRM (published 2026-10-08)
- Study in the States, DHS publishes proposed rule establishing fees for OPT (where it differs from the Federal Register text, the Federal Register controls)
- ICE/SEVP, BCM 2608-01 and BCM 2608-02
This article explains how OPT works. It is not legal advice. For anything on your SEVIS record or OPT recommendation, your DSO is the right person; for a status problem or a decision with immigration consequences beyond F-1, speak with a licensed immigration attorney.
If you are mapping your OPT months against a job search that has to land before the clock runs out, F1Jobs can talk you through how we help international students target employers that sponsor.
Frequently asked questions
Does pre-completion OPT reduce my post-completion OPT?
Yes. You get 12 months of OPT per degree level, and pre-completion and post-completion OPT draw from the same pool. Full-time pre-completion OPT is deducted month for month, and part-time pre-completion OPT is deducted at half the full-time rate. Whatever you use before graduation is gone from the post-completion period.
Would the proposed $70,000 OPT fee apply to pre-completion OPT?
Under the DHS proposal published on October 8, 2026, yes. The NPRM covers any type of OPT, so a pre-completion recommendation would be your initial recommendation at $70,000 and a later post-completion recommendation would cost $30,000. It is only a proposal, the school is the legal payer, and it would apply only to DSO recommendations dated 60 or more days after a final rule.
Is OPT or CPT better for an internship during my degree?
They are different authorizations with different costs to your future time. CPT does not draw down your OPT months, and the OPT fee proposal does not cover CPT, but SEVP guidance issued in August 2026 has narrowed when schools can authorize CPT and that guidance is being challenged in court. Which one fits your internship is a question for your DSO, who controls both recommendations.
Does the 90-day unemployment limit apply to pre-completion OPT?
The 90-day unemployment limit is a post-completion OPT rule, and it rises to 150 days in aggregate if you receive the 24-month STEM extension. Pre-completion OPT is tied to your enrollment rather than an unemployment counter. Your DSO can confirm how your own SEVIS record is tracked.
Can I still get STEM OPT if I used pre-completion OPT?
STEM OPT is an extension of a period of post-completion OPT, so you need post-completion OPT time left to extend from. Using part of your 12 months before graduation shortens post-completion OPT, and using all 12 months would leave no post-completion period at that degree level. Confirm the exact effect on your record with your DSO before you file.