DHS Final Rule to End Duration of Status and Impose F-1 Academic Restrictions

Until now, F-1 students and J-1 exchange visitors have generally been admitted to the United States for Duration of Status (D/S), allowing them to remain in the U.S. as long as they complied with the requirements of their immigration status. 

Under the new DHS rule, F-1 and J-1 students and scholars will instead be admitted for a fixed period of time shown on their Form I-94. In most cases, the admission period will be tied to the program end date on the Form I-20 or DS-2019 plus a 30-day grace period and will be limited to a maximum of four years. 

As a result, individuals admitted under the new rule will: 

• Receive a specific expiration date on their Form I-94 instead of "D/S." 
• Be admitted until the program or appointment end date on their Form I-20 or DS-2019, or four years, whichever is shorter. 
• Be responsible for monitoring their I-94 expiration date. 
• Need to obtain an Extension of Stay (EOS) from USCIS or depart and re-enter the United States if additional time is needed beyond their authorized admission period. 
• Receive a 30-day grace period after completing their program or authorized activity. 

The rule affects individuals in F and J status, including:  

• F-1 students; 
• F-2 dependents;  
• J-1 students, scholars, researchers, professors, and other exchange visitors; and  
• J-2 dependents.  

The rule may impact individuals differently depending on their immigration status, program length, travel plans, academic progress, employment authorization, and other future plans. 

If you are already in the US in F-1 or J-1 status, your I-94 will continue to have a D/S end-date until the next time you travel, after which you will be admitted until your program end date.  This exception will be in effect until 2030.  

In the meantime, we encourage all of you in F-1 and J-1 status to: 

• Review the program end date on your current Form I-20 or DS-2019;  
• Review your most recent Form I-94 record;  
• Notify OISS promptly if your program, academic plan, research activity, appointment, funding, or expected completion date may change, or if you expect to stay in the US beyond your program end date;  

Consult OISS before pursuing a transfer, change in major or educational objective, change in degree level, program extension, OPT, STEM OPT, Academic Training, or other significant immigration-related change. 

This is the most fundamental change. Once the rule takes effect, F-1 students and J-1 exchange visitors will be admitted for a fixed date (“Admit Until Date” or AUD) as recorded on their I-94 Arrival Record. 

For most students and exchange visitors, DHS will admit them until the end date of their Form I-20 or DS-2019 (i.e., their program end date), not to exceed four years, plus a 30-day grace period.

F-1 and J-1 students and scholars, and their dependents, will now be required to carefully track their fixed admission periods. You will need to carefully monitor your I-20 or DS-2019 program end date and your I-94 expiration date, and, if needed, file a timely extension of stay.  

One of the most significant changes under the new rule is that extending a program, appointment, or training authorization may no longer be accomplished solely through OISS and an updated Form I-20 or DS-2019. 

Under the new rule, an updated Form I-20 or DS-2019 will not automatically extend the expiration date on a student's or scholar's Form I-94. Instead, individuals who need additional time beyond their current period of admission may need to obtain a new period of authorized stay. 

An extension of stay may be necessary for a variety of reasons, including:  

• Completing a degree program that requires additional time;  
• Beginning a new academic program or degree level;  
• Participating in post-completion OPT or STEM OPT;  
• Participating in J-1 Academic Training; or  
• Extending a J-1 research, teaching, or exchange program.  

In most cases, individuals who need additional time will have two options: 

• Apply for an Extension of Stay (EOS) with USCIS before their I-94 expires; or  
• Travel abroad and re-enter the United States with valid immigration documents to receive a new period of admission and updated I-94.  

Each option has different requirements, timelines, costs, and potential travel considerations, and the most appropriate path will depend on the individual's circumstances. OISS will provide guidance as additional implementation details become available. 

In summary, the rule establishes a 2-step process for F-1 students and J-1 exchange visitors who need more time: 

• Step 1 would be for the DSO or RO to recommend an extension using SEVIS procedures similar (or exactly the same) as those they use now to obtain a Form I-20 or DS-2019 for a program extensions, moving educational levels, transfer to a new school or exchange program, F-1 post-completion OPT or STEM OPT recommendation or J-1 academic training 
• Step 2 would be for the student or exchange visitor (and their dependents) to timely file a full extension of stay application on Form I-539, with fee, which would have to be adjudicated by USCIS under revised standards OR travel outside the US and re-enter the US to obtain a new admit until date. 
   

DSOs will only be able to extend a student’s SEVIS record to allow for more time to complete the same program for: 

• A compelling academic reason, such as a change of major or research topic or unexpected research problems. Unexpected research problems are those caused by an unexpected change in faculty advisor, need to refine an investigatory topic based on initial research, research funding delays, and similar issues. Delays including, but not limited to, those caused by academic probation or suspension or a student’s repeated inability or unwillingness to complete his or her course of study are not acceptable reasons for an extension 
• A documented illness or medical condition that is a compelling medical reason, such as a serious injury, that is supported by medical documentation from a licensed medical doctor, a licensed doctor of osteopathy, a licensed psychologist, or a licensed clinical psychologist; or 
• Circumstances beyond the student’s control – including a natural disaster, national health crisis, or the closure of an institution.   

The new rule creates a new regulatory concept called "educational objectives," which DHS defines as a student's major or educational level. As a result, F-1 students will face new restrictions on changing majors, transferring schools, and pursuing additional degree programs. The restrictions differ substantially for undergraduate and graduate students. 

Undergraduate Students  

Students below the graduate level retain some flexibility, but with new restrictions. According to the new rule, during the first academic year, an undergraduate F-1 student may not: 

• transfer to another school, 
• change majors, or 
• change educational levels, 

unless SEVP approves an exception due to extenuating circumstances, such as a school closure or another extraordinary event. 

Once the first academic year has been completed, undergraduate students may transfer to another institution, change majors, and change educational levels.   

Graduate Students  

The final rule is considerably more restrictive for graduate students. With the new rule, an F-1 student at the graduate level or above will no longer be able to change educational objectives at any point during their program of study. 

This means a graduate student generally cannot: 

• change majors; 
• change degree programs; or 
• change educational levels 

Graduate students may not transfer to another school during their program of study. Under the new rule, F-1 students at the graduate level are generally prohibited from transferring institutions while enrolled in their current program. Exceptions are limited and may be granted only in certain circumstances approved by SEVP, such as a school closure or other extenuating circumstances. 
 

No lateral or downward/reverse progression after program completion

The final rule also expects students to move to a higher educational level after completing a program. According to the new rule, after completing a program, an F-1 student may not begin another program at the same or lower educational level while maintaining F-1 status.

The rule will affect how F-1 students plan for Optional Practical Training (OPT) and STEM OPT, and how J-1 exchange visitors plan for Academic Training (AT).  When you apply for post-completion work authorization, be sure to pay close attention to your I-94 expiration date and consult OISS well in advance of any need for an extension of stay. 
 
An approved Employment Authorization Document (EAD) does not, by itself, extend your authorized period of stay, so additional applications to USCIS may be required. 
 
Students who are already present in the US with a D/S end-date when this rule goes into effect may may apply for OPT authorization without also having to request an Extension of Status until March 17, 2027 after which they will have to have their Extension approved by USCIS.  

The rule shortens the F-1 grace period from 60 to 30 days, aligning it with the J-1 visa classification. 

This will affect departure, transfer, change of status, change of level, and practical training (OPT) timelines. Students will have much less time after graduation to make immigration decisions. 
 
Under the transition provisions, F-1 students who were admitted to the U.S. for Duration of Status (D/S) before September 15, 2026 will generally continue to benefit from the existing 60-day post-completion grace period. This will remain true until the student either travels outside the U.S. and is readmitted according to the new rule or obtains an Extension of Stay approved by USCIS. 

Once the student is issued a new Form I-94 through either readmission after travel or USCIS adjudication of an Extension of Stay application, the student will be subject to the new fixed-period admission rules, including a specific Admit Until Date (AUD) and the new 30-day post-completion grace period. 

Under the new rule, your I-94 expiration date will become especially important. Remaining in the United States beyond the authorized date on your I-94 without a timely filed extension application will result in a loss of immigration status and will lead to the accrual of unlawful presence starting from your I-94 expiration date. 
 
Please review your I-94 record after every entry to the United States and do not assume that the end date on your I-20, DS-2019, visa stamp, EAD, or passport controls your authorized period of stay.  Only your I-94 will control your authorized stay.   This is a marked departure from the previous rule in which your stay was determined by your I-20.  

To help you maintain your immigration status, OISS has updated its reporting requirements in the ISS Portal: 

•  New Student Immigration Check-In: Required of new F-1 and J-1 visa holders upon arrival at the start of your program. 
• Returning Student Immigration Check-In: Required of all continuing F-1 and J-1 students at the start of each fall and spring semester. 
• I-94 Update Form: Required of all continuing F-1 and J-1 students and scholars after international travel during the semester. 

Form I-94 Resources 

Because the new rule makes the Form I-94 the primary document governing a student's or scholar's authorized period of stay, understanding and monitoring your I-94 record will become increasingly important. 

• OISS Website: I-94 Arrival/Departure Record 
• SEVP overview explaining the purpose of the I-94 and why it is important: Study in the States: Understanding the Form I-94 
• Official CBP website to retrieve and print your electronic Form I-94 admission record. (I94): CBP I-94 Retrieval Website