STEM OPT Fees Under the Proposed Rule: $30,000, $70,000 or $100,000? Six Student Scenarios Worked Out

The proposed OPT fee rule could mean $0, $30,000, $70,000 or $100,000 for your OPT path. Six worked scenarios show which number is actually yours.

If you are on F-1 and planning for OPT or the 24-month STEM extension, you have probably seen three numbers this week: $30,000, $70,000 and $100,000. Here is the short answer on STEM OPT fees. Under a DHS proposal published on 2026-10-08, a STEM OPT recommendation would carry a $30,000 fee. Your first OPT recommendation would carry $70,000. Initial OPT plus STEM OPT, both under the new rule, totals $100,000. Your school would be billed, not you directly, and it may pass the cost on to you.

Right now the fee is proposed, not in effect, with no effective date. Your number depends on which recommendations you still need, when your DSO dates them, and what your school does with the bill. The six scenarios below work through those combinations.

Status as of 2026-10-13:

• In effect today: the current Form I-765 fee and the $1,780 OPT/STEM OPT premium processing fee (G-1055, edition 10/07/26). Both are unchanged.
• Proposed: the "Optional Practical Training Fees" NPRM (91 FR 64566), published 2026-10-08. Comments close 2026-11-09. There is no final rule and no effective date.
• Scheduled: nothing.

What the proposed OPT fee rule actually says

DHS and ICE published the NPRM in the Federal Register under docket ICEB-2026-0100. SEVP posted its own summary on Study in the States. These are the provisions that set your number:

• $70,000 before a student's initial OPT recommendation. "Initial" covers whichever OPT comes first, pre-completion or post-completion.
• $30,000 before each subsequent OPT recommendation. STEM OPT counts as subsequent. So does post-completion OPT if you already used pre-completion OPT.
• The SEVP-certified school pays, before the DSO issues the recommendation. The proposed text says USCIS may not grant employment authorization when the DSO's recommendation came before the school paid. DHS states that schools may pass the cost to F-1 students, to all students, or to employers.
• Prospective only. The fee would apply only to DSO recommendations dated 60 or more days after a final rule is published. Read alongside that transition clause, OPT that is already authorized does not appear to be affected. That reading is inferred, not a sentence in the rule, so confirm it with your DSO.
• CPT is out of scope. Curricular Practical Training carries no fee under this proposal.
• Refunds are discretionary, possible only before the EAD is issued, and "not subject to any administrative appeals."

Sources disagree on one point, and it matters for STEM students. SEVP's summary describes $30,000 "for the second year" with no further fees. The Federal Register text charges $30,000 for each subsequent recommendation, and it controls. That is the version used below.

For the fees you would pay today with no rule change, see our full STEM OPT application cost breakdown.

How the fee could start: the timeline

The proposed fee cannot reach anyone until each of these steps has happened:

1. 2026-10-08: NPRM published. It is a proposal, not law.
2. 2026-11-09: public comment period closes. Paperwork Reduction Act comments run to 2026-12-07.
3. Unknown date: DHS reviews the comments and publishes a final rule. The final rule could match the proposal, lower the amounts, raise them, or never be published at all.
4. Final rule + 60 days: the trigger date. Only DSO recommendations dated on or after it would be covered.
5. Before each covered recommendation: your school pays the fee to the Treasury, then the DSO enters the recommendation in SEVIS.
6. After that: you file Form I-765 with USCIS as you do now. You pay the regular filing fee, plus premium processing if you choose it.

Practitioners expect litigation if the rule is finalized, and NAFSA has said it will file detailed comments. Both add uncertainty to step 3.

STEM OPT fees in six scenarios, worked out

All six assume the rule is finalized exactly as proposed. They show the fee assessed on the school. What you personally pay could be anywhere from $0 to that full amount, depending on your school's pass-through policy.

Scenario 1: You are on post-completion OPT now and plan to apply for STEM OPT

Your post-completion EAD is already approved, and your STEM extension window is a year away.

• Your current OPT is already authorized, so it is not affected.
• If your DSO's STEM OPT recommendation is dated before the trigger date, no new fee applies.
• If it is dated on or after the trigger date, it is a subsequent recommendation: $30,000.

This is where the OPT STEM extension fee matters most to people already working. The date that counts is your DSO's recommendation date, not your USCIS filing date or graduation date. The usual extension steps still apply (DSO recommendation, I-983, filing before your current EAD expires). Our STEM OPT vs OPT vs CPT comparison covers that sequence.

Scenario 2: You graduate after the trigger date and want post-completion OPT only

You are in a non-STEM master's program and expect to finish after any final rule takes effect.

• Your post-completion OPT recommendation is your initial recommendation: $70,000.
• You are not eligible for a STEM extension, so there is no further fee.

Scenario 3: You are a STEM graduate who needs both initial OPT and STEM OPT after the trigger date

• Initial post-completion OPT recommendation: $70,000.
• STEM OPT recommendation about a year later, near the end of your 12-month post-completion OPT: $30,000.
• Total: $100,000. This is the second worked example in the NPRM itself.

Scenario 4: You use pre-completion OPT, then post-completion OPT

You take part-time pre-completion OPT during your program, then post-completion OPT after you graduate.

• Pre-completion OPT is your initial recommendation: $70,000.
• Post-completion OPT is a subsequent recommendation: $30,000.
• Total: $100,000. This is the NPRM's first worked example.

If you later need a STEM OPT recommendation too, the regulatory text charges another $30,000, since every subsequent recommendation is charged. Under this proposal, pre-completion OPT changes the math, so ask your DSO before you request it.

Scenario 5: You only use CPT

Your program builds in internships through Curricular Practical Training, and you do not plan to apply for OPT.

• CPT is out of scope: $0 under this rule.
• That does not mean CPT is risk-free. SEVP's 2026 CPT broadcasts (BCM 2608-01 and 2608-02) are in effect as guidance and are being challenged in AAU v. DHS, with a hearing set for 2026-11-06. CPT eligibility is a separate question to take to your DSO.

Scenario 6: Your recommendation is dated before the trigger, or the rule is never finalized

• No OPT fee applies.
• You pay what students pay today: the current I-765 filing fee, plus the optional $1,780 premium processing fee if you choose it.

As of mid-October 2026, this is every student's situation, because there is no final rule.

The six scenarios side by side (as of October 2026)

The fees you pay USCIS directly are a separate line, listed on the USCIS G-1055 fee schedule and the Form I-765 page. Check both for the base filing amount before you file.

Old rule, proposed rule, what to do differently

For budgeting what you pay USCIS directly, our OPT fee planning guide built around the $1,780 figure still applies. That $1,780 is the premium processing fee, not a program fee, and this NPRM does not change it.

What this means for your job search

Some recruiters may assume OPT candidates now cost $70,000 or $100,000 to hire. Today that is false: the fee is proposed. If it is finalized, the school is the legal payer, and an employer pays only if the school passes the cost on to employers.

If your STEM OPT window falls after a possible trigger date, talk to your DSO before discussing a pass-through with an employer. The STEM extension's other requirements have not changed: an E-Verify employer, a Form I-983 training plan, and the 150-day aggregate unemployment limit set out in SEVP's unemployment guidance on ice.gov.

DHS's press release on 2026-10-07 said OPT "was never meant to be a back door into the American workforce." The NPRM also says DHS "may shut down the program entirely" without fees. A separate, broader review of OPT and STEM OPT has been announced but not published. Plan with the possibility of more changes in mind.

How to comment on the proposal

Anyone can comment on docket ICEB-2026-0100 through the Federal Register page linked above (it routes to regulations.gov) until 2026-11-09. Specific, factual comments, such as how a fee would affect your program, school or employer, carry the most weight. Commenting is a public act, so leave your SEVIS ID and other private identifiers out of it.

Common mistakes

• Saying "OPT now costs $70,000." It does not. The fee is proposed, with no effective date.
• Assuming you will receive the bill. The school pays. Whether you are charged depends on a policy most schools have not written yet.
• Using your graduation date or USCIS filing date as the trigger. The proposal keys off the date of the DSO's recommendation compared with final rule + 60 days.
• Treating $30,000 as a one-time STEM add-on in every case. The Federal Register text charges $30,000 for each subsequent recommendation, and pre-completion OPT changes your count.
• Mixing up the $1,780 figure with the proposed fee. $1,780 is the optional USCIS premium processing fee. It is unchanged.
• Assuming CPT is a safe workaround. CPT is outside this fee, but CPT has its own guidance and its own pending litigation. Any decision about it belongs with your DSO.

Frequently asked questions

How much would the STEM OPT fee be under the proposed rule?

The DHS proposal published on 2026-10-08 sets $30,000 for each subsequent OPT recommendation, and STEM OPT counts as a subsequent recommendation. If your initial OPT recommendation is also covered, that adds $70,000, which is how the NPRM reaches $100,000 for initial OPT plus STEM OPT. It is a proposal with no effective date, so nobody owes it today.

Would I have to pay the OPT fee myself?

Not automatically. Under the proposed text, the SEVP-certified school pays the fee before the DSO issues the recommendation. DHS says a school may pass the cost on to F-1 students, to all students, or to employers, so what you personally pay depends on your school's policy if the rule is finalized.

Does the proposed fee apply if my OPT is already approved?

The proposal applies only to DSO recommendations dated 60 or more days after a final rule is published, so OPT that is already authorized appears to be unaffected. A later STEM OPT recommendation dated after that point would be a subsequent recommendation and would carry the $30,000 fee as proposed. Confirm your own dates with your DSO.

When could the new STEM OPT fees start?

There is no start date yet. Comments on the NPRM close on 2026-11-09, DHS then has to publish a final rule, and the fee would reach only DSO recommendations dated 60 or more days after that final rule. DHS could also change the amounts or drop the proposal.

Has the USCIS STEM OPT fee changed today?

No. As of October 2026 the current Form I-765 filing fee is unchanged, and the optional premium processing fee for an OPT or STEM OPT I-765 remains $1,780 under the G-1055 fee schedule edition dated 10/07/26. Check the live USCIS I-765 page before you file.

This post explains how the proposal works. It is not legal advice. For any OPT, STEM OPT or SEVIS decision, your DSO is the right person to ask. For questions outside F-1 status, ask a licensed immigration attorney.

While the rule is still a proposal, your job search goes on. If you want help targeting employers that hire OPT and STEM OPT candidates, talk to F1Jobs.