STEM OPT Employer Requirements and the I-983 Training Plan 2026

Your STEM OPT extension hinges on one document your employer has to sign — here is exactly how to get it right before the 90-day clock starts.

You applied for your STEM OPT extension, your DSO approved the recommendation, USCIS issued your new EAD card — and now your employer's HR team is asking you to explain what the I-983 is, why they need to sign it, and what E-Verify has to do with any of this. This is the exact moment most international students realize they don't know the details well enough to explain them to the person who needs to cooperate.

The 24-month STEM OPT extension is one of the most valuable work authorizations available to international graduates, but it comes with structural requirements that your employer must satisfy. Getting those requirements wrong — or discovering them too late — can collapse your timeline, trigger the 90-day unemployment clock, and put you closer to a status gap than you should ever be. This guide walks through every employer-facing requirement in concrete, actionable terms so you can go into those HR conversations prepared.

Who qualifies for STEM OPT — a quick baseline

Before getting into employer mechanics, confirm you're actually eligible. STEM OPT is a 24-month extension of the standard 12-month OPT work authorization for F-1 students who:

• Hold a qualifying STEM degree (check the DHS STEM Designated Degree Program List — not every science or engineering degree qualifies)
• Are working in a job directly related to that STEM degree field
• Have an employer that is enrolled in E-Verify
• Submit the I-983 Training Plan to their DSO before the extension is recommended

If you're still weighing whether OPT, STEM OPT, or CPT is the right path for your situation, the OPT vs STEM OPT vs CPT comparison covers the strategic differences.

The E-Verify requirement — no exceptions

E-Verify is a federal employment eligibility verification system administered jointly by DHS and the Social Security Administration. For STEM OPT purposes, it's a binary requirement: your employer is enrolled, or they are not eligible to employ you on STEM OPT.

How to check employer E-Verify status:

1. Go to e-verify.uscis.gov
2. Use the "Search for a Company" feature
3. Enter the employer's legal name (not their trade name)
4. Confirm their status shows as active

Employers self-register on E-Verify at no cost. If your prospective employer isn't enrolled, they can register at uscis.gov/e-verify — the process typically takes a few days and requires a Memorandum of Understanding with DHS. This is a legitimate ask you can make of any employer, though some smaller employers may be unfamiliar with it.

Multi-site employer note: Large companies often have E-Verify at the corporate level, covering all subsidiaries. Smaller operations may be enrolled at only certain office locations. Confirm that the specific legal entity employing you — the entity appearing on your I-9 and W-2 — is the enrolled entity.

What the I-983 Training Plan actually requires

The I-983 (formally the "Training Plan for STEM OPT Students") is a multi-page form that creates a binding agreement among three parties: you, your employer, and your DSO. Here is what each section covers:

The most commonly weak section is Goals and Objectives. USCIS has flagged vague training plans as grounds for RFE or denial in site visits. The learning objectives must be specific to your STEM field — "improve my software engineering skills" is not sufficient. "Apply machine learning algorithms to optimize inventory forecasting pipelines using Python and TensorFlow" is the level of specificity required.

Completing the I-983 step by step

Step 1 — Gather employer information before your first meeting

Before you sit down with HR, collect the following:

1. Employer's legal business name (as registered with IRS)
2. Employer Identification Number (EIN) — on your offer letter or W-2
3. E-Verify Company ID — HR should be able to look this up in their E-Verify portal
4. Named supervisor's full name and title
5. Physical worksite address (remote work arrangements need special handling — see below)

Step 2 — Draft the training objectives yourself

Do not ask HR to write your training objectives. They don't understand what USCIS expects, and generic HR language won't pass scrutiny. Draft 4-6 specific learning goals that:

• Use technical vocabulary from your STEM field
• Connect the job tasks to skills from your degree program
• Are measurable (you should be able to say whether you achieved them)
• Map to what you will actually do in the role

Step 3 — Get the employer signature from an authorized signatory

The I-983 must be signed by someone with authority to bind the employer — typically a VP, Director of HR, or another officer-level employee. A hiring manager or recruiter usually lacks the authority USCIS expects. Check with your HR department to confirm who in their organization is authorized to sign immigration-related attestations.

Step 4 — Submit to your DSO before the extension recommendation

Your DSO cannot recommend the STEM OPT extension on your SEVIS record until they have a signed I-983 on file. Submit the completed form — student sections and employer sections — to your international student office. Processing times vary by school, so do this at least 3-4 weeks before you need the recommendation.

Step 5 — Retain copies

Keep copies of the signed I-983, your employer's E-Verify enrollment confirmation, and all correspondence. If USCIS conducts a site visit or sends a Notice of Intent to Terminate, you will need to produce these quickly.

Remote work and third-party placement arrangements

Remote work has created compliance ambiguity for STEM OPT. If you are working fully remotely, the "worksite" on the I-983 is generally your home address — but your employer's E-Verify enrollment must still be in order. USCIS requires the employer to identify how they will supervise and evaluate a remote employee; your I-983 supervision section should describe the remote oversight structure explicitly.

For third-party placements (staffing agencies, consulting firms placing you at a client site), two questions come up:

1. Whose E-Verify matters? The employing entity — the one issuing your W-2 — must be E-Verify enrolled. The end client does not need to be enrolled.
2. Who signs the I-983? The employing entity signs, but the I-983 should reflect the actual supervision structure. If the day-to-day supervisor is at the client site, name them and explain the relationship.

If you are at a consulting firm that places you at client sites and you're unsure about any of this, read our guide on finding OPT-friendly employers for a framework on vetting sponsor quality before accepting an offer.

The reporting and evaluation cycle

STEM OPT is not a "sign it once and forget it" authorization. Both you and your employer have ongoing obligations:

12-month evaluation (required)

At the one-year mark of your 24-month extension, your employer must complete a formal evaluation and submit an updated I-983 to your DSO. This evaluation covers whether you are meeting the training objectives, any changes to duties or supervision, and a confirmation that the employment relationship is continuing. Your DSO must receive this before the 12-month anniversary passes.

End-of-extension evaluation (required)

Within 30 days of the extension period ending, your employer submits a final evaluation. If you transition to H-1B before the STEM OPT period expires, the evaluation is still required for the period you were on STEM OPT.

Material change reporting

If any of the following change, your DSO needs an amended I-983 before the change takes effect:

• Change in employer (new company)
• Change in job duties that is material to the training plan
• Change in worksite location
• Change in compensation falling significantly below similarly-situated workers
• Change in named supervisor

Minor day-to-day task variation within the same role does not require an amendment.

What "comparable wages" actually means

The I-983 requires that your compensation be comparable to similarly-situated US workers in the same role and geographic area. This is not an arbitrary formality — USCIS and ICE use wage comparisons during site visits to detect exploitation of STEM OPT workers.

For practical purposes: look up prevailing wages on the DOL Foreign Labor Certification Data Center (flcdatacenter.com) for your job title and metropolitan area. Your salary should be at least at the Level 1 wage for your role. If your offer comes in significantly below that, that is a red flag — not just for compliance, but for whether this employer will support your eventual H-1B sponsorship.

How STEM OPT fits into the path to H-1B

The STEM OPT extension gives you up to 36 months of total work authorization (12 OPT + 24 STEM OPT) from graduation. That window is what makes the F-1 path viable for most international graduates — it covers two H-1B lottery cycles, sometimes three.

Here is a simplified timeline for graduates targeting H-1B from STEM OPT:

1. Graduate — OPT 12-month clock begins
2. Month 1-3 — File OPT EAD, begin working
3. Month 10-11 — Apply for STEM OPT extension (apply 90 days before OPT expires)
4. Month 12 — OPT expires, STEM OPT begins (24 months)
5. April of Year 1 on STEM OPT — First H-1B lottery entry
6. April of Year 2 on STEM OPT — Second H-1B lottery entry if Year 1 didn't work
7. STEM OPT ends ~Month 36 — Must have H-1B cap-gap, change of status, or another path

If you miss both lottery rounds, you need backup plans. STEM OPT buys you the runway, but you need to be executing on H-1B preparation during STEM OPT, not after it.

Also relevant: the cap-gap extension protects F-1 students who win the H-1B lottery in April of their OPT year — your status is automatically extended through October 1 when the H-1B becomes effective. The H-1B Modernization Rule (effective January 2025) extended the cap-gap period to April 1 of the relevant fiscal year.

Common mistakes

Assuming your employer knows what E-Verify is. Many small and mid-size employers have never hired an international student. You may need to explain what E-Verify is, why enrollment is required, and how to register. Have the DHS E-Verify registration link ready.

Writing vague training objectives. "Gain experience in software development" will not survive USCIS scrutiny. Specificity — named technologies, methodologies, measurable outcomes — is what makes an I-983 credible. Spend the time to write objectives that actually describe your work.

Getting the wrong person to sign. An I-983 signed by a recruiter or junior HR coordinator may lack the authority USCIS expects. Confirm that the signatory holds a title with authority to bind the employer to immigration-related attestations.

Missing the 12-month evaluation. This is a common compliance failure because it falls in the middle of the extension and both parties forget about it. Set a calendar reminder 60 days before the one-year mark of your STEM OPT extension and send your supervisor a reminder.

Not reporting employer or duty changes promptly. Working in a materially different role without an amended I-983 on file at your DSO puts your status at risk. When something changes, update your DSO first, then your employment paperwork.

Selecting employers with poor immigration track records. STEM OPT is a stepping stone. If your employer won't sign the I-983 properly, won't participate in the evaluation cycle, or balks at E-Verify enrollment, that is a signal about how they'll handle H-1B sponsorship later. Use resources for checking H-1B sponsorship history when evaluating offers.

Ignoring the 90-day unemployment limit. The 90-day clock runs from when you are unemployed on OPT, not just STEM OPT — the counts are cumulative. If you spent 60 days unemployed during your initial OPT, you only have 30 days left during STEM OPT. Track this precisely.

Frequently asked questions

What is the I-983 Training Plan for STEM OPT? The I-983 is a USCIS form that creates a formal training agreement between you, your employer, and your DSO. It describes the job duties, learning goals, salary, and supervision plan for your 24-month STEM OPT extension period. USCIS requires it before your DSO can recommend the extension on your SEVIS record. Without a completed and signed I-983, your extension application cannot move forward.

Does my STEM OPT employer need to be on E-Verify? Yes. E-Verify enrollment is a hard requirement — not a preference. Your employer must have an active E-Verify company ID before your DSO recommends the STEM OPT extension. You can verify enrollment at e-verify.uscis.gov using the employer search. If your employer is not enrolled, they need to register at no cost before you can use them for STEM OPT.

How often does the I-983 need to be updated during STEM OPT? Your employer must conduct formal evaluations and provide an updated I-983 to your DSO at the 12-month mark of the 24-month extension, and again within 30 days of the extension period ending. If your role changes materially — different duties, new worksite, different supervisor — your DSO needs an amended I-983 before that change takes effect. Day-to-day variation within the same role does not require an update.

Can a staffing agency be my STEM OPT employer? Yes, but with restrictions. The staffing agency itself must be on E-Verify, and the I-983 must reflect the actual day-to-day work location and supervisor. USCIS looks closely at staffing-agency I-983 forms because they often lack specific learning objectives tied to a real worksite. Both the staffing agency and the end client sometimes need to be named, depending on how supervision is structured. Consult your DSO before accepting a staffing-agency placement.

What happens if I lose my STEM OPT job before the 24 months are up? You have a 60-day grace period from the date of termination to find a new employer, transfer to a different visa status, or depart the US. During this grace period you are not authorized to work. The 60-day period does not reset your 90-day unemployment limit — it counts against it. If you find a new qualifying employer within 60 days, your DSO reports the change in SEVIS and you submit a new I-983 with the new employer.

Questions about your specific STEM OPT situation, employer vetting, or H-1B next steps? F1Jobs — we help international graduates navigate these transitions every week.