OIRA completed its review of the OPT fee proposal, with changes, on September 11, but the proposal text is not yet public. The $100,000 figure comes from media reports: the official amount, who pays, which applications are covered and any exemptions are all unpublished, so payment by students, employers or schools cannot be assumed. The fee is not in effect, and the current OPT filing fee is unchanged.
Who is affected
F-1 students planning OPT or a STEM OPT extension and their employers.
Key boundaries
The payer, covered applications and exemptions are unpublished; $100,000 is media-reported and student payment cannot be assumed.
Next to watch
Await a published NPRM to confirm the amount, payer, coverage and comment deadline.
Review scope
The September 11 OIRA conclusion and current Federal Register RIN search were reviewed September 24 along with accessible forum replies. No public NPRM was verified. The official amount, payer and scope await published text; forum replies are not official terms.
Policy background
00 / BACKGROUND
ICE submitted Optional Practical Training Fees on August 20, 2026; the September 11 OIRA conclusion is Consistent with Change. Completed prepublication review is not a final rule or an effective fee. No public NPRM was located; payment responsibility awaits official provisions.
Potential impact
01 / IMPACT
OUR TAKE · ANALYSIS
The first U.S. job after graduation could come with a steep entry cost.
If a $100,000 fee is broadly implemented, it could significantly change the economics of working in the U.S. Students would need greater financial capacity, employers covering the fee could raise the bar for new-graduate hiring, and the pressure would arrive before the H-1B transition.
For students: financing comes before returns
If applicants must pay when filing, the expense would come before they earn income from the job. Students with limited savings, education debt, or lower expected starting salaries would face a greater challenge in making U.S. employment financially viable.
Example 1 · Hypothetical
Lin is finishing a master’s and has a full-time offer, with plans to start after obtaining OPT. If the final rule requires the student to pay $100,000 when applying, Lin would need that money before receiving a first paycheck. If neither Lin nor the family can afford it, the offer alone would not make starting work through OPT possible. This assumes the student pays; the payer has not been announced.
Example 2 · Hypothetical
Zhou is deciding whether to accept a US master’s offer. The family has budgeted for tuition and living costs and hopes Zhou will work in the US afterward. If OPT later requires another $100,000 from the student, that work plan would carry a cost outside the original budget. The possible fee could affect the admission decision now, not only decisions after graduation.
For employers: new-graduate offers may become harder to secure
If employers pay, they would commit more money before an employee has demonstrated value. Entry-level roles and small companies with limited budgets may be more sensitive and may favor candidates who can produce returns sooner.
For example · Hypothetical
A small company has budgeted a salary for new graduate Chen. If the final rule makes the employer responsible for the OPT fee, or the company chooses to cover it, the company would need another $100,000 beyond salary. Without a larger hiring budget, it might withdraw or delay the offer because of the added cost, not because Chen is unsuitable for the role.
For the U.S. pathway: pressure moves to the OPT stage
For students who rely on OPT to begin working and later seek H-1B status, a high fee could make that bridge less accessible. Employer support for the fee and job options in other places may become more important.
Outlook
02 / OUTLOOK
Our outlook: the next debate will center on who pays, who is exempt, and who is affected. Those provisions will determine whether the cost falls mainly on student finances, employer hiring budgets, or particular applicants.
What happens in each case?
Choose a situation below to see its possible effects. These are alternatives, not steps or predictions of likelihood.
IF THIS HAPPENS A · Broad high fee
The standard OPT path becomes far less affordable
Assumption: The $100,000 fee applies to most new applications, with limited relief.
Potential effects in this scenario
Students may be less willing to fund a U.S. job search themselves, while employers may tighten new-graduate hiring. Applicants with financial resources and employers able to absorb the cost would have a relative advantage.
Signals to watch
A formal proposal keeps the fee at this level, applies it broadly, and provides no meaningful waiver or transition protection.
These scenarios are our analysis, not probability rankings. We revise them as evidence changes.
Which boundaries could change this analysis?
Who pays
Student payment affects cash flow; employer payment changes the cost-benefit calculation for hiring.
Covered applications
Initial OPT, STEM extensions, exempt groups, and protection for existing cases.
Effective date and transition
Filing cutoffs and transition periods determine which graduating classes are affected.
Progress
03 / Federal rulemaking
OIRA completed OPT fee proposal review with changes on September 11. No public NPRM was located; the amount and payer are unpublished and the fee is not in effect.
Currently waiting for
Publication of an NPRM and comment period, specifying the amount, payer and coverage.
Last completed · OIRA review
OIRA reviews the proposal before publication.
Key dates
04 / TIMELINE
RIN 1653-AB01 was submitted to OMB/OIRA for review.
Universities cautioned that the $100,000 figure came from media reporting, not a published government document.
OIRA completed review with changes; this does not mean an NPRM was published or a fee took effect.