For more than thirty years, F-1 students have been admitted to the United States for "duration of status," or D/S. Your I-94 read "D/S" instead of a calendar date, and as long as you stayed enrolled, made academic progress, and your DSO kept your SEVIS record current, you didn't have to ask the federal government for permission to stay in the country.

That framework is what the Department of Homeland Security has proposed to end.

If you're an F-1 student, an OPT or STEM OPT holder, or someone considering a Change of Status into F-1, the proposed rule would replace the system you've been operating under. In its place: a fixed admission date on your I-94, a four-year cap regardless of your program length, a shorter grace period after you finish, and a new requirement to file an extension of stay application directly with USCIS when you need more time.

This post walks through what the proposed rule actually says, what an extension of stay would look like in practice, who it affects most, and what you can do right now to keep your plans on track. One thing to be clear about up front: as of May 2026, this is a proposed rule. Nothing has changed yet. I-94s still read "D/S." Your status today is not different from what it was last week. But the rule is far enough along that ignoring it is a worse plan than preparing for it.

DHS published the Notice of Proposed Rulemaking (NPRM) in the Federal Register on August 28, 2025, under the title "Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure for Nonimmigrant Academic Students, Exchange Visitors, and Representatives of Foreign Information Media." The public comment period closed on September 29, 2025, and the rule attracted close to 22,000 public comments.

The core provisions:

1. End of Duration of Status. Instead of "D/S," your I-94 would carry a specific admit-until date. That date would be the earlier of your I-20 program end date or four years from your date of admission to the U.S.
2. Four-year cap. Even if your I-20 reflects a longer program, your initial admission would not exceed four years. Anyone needing more time would have to file for an extension of stay.
3. Extension of stay via Form I-539. Students who need to remain in the U.S. beyond their admit-until date would file Form I-539 with USCIS. The current filing fees are $470 by paper or $420 online, and DHS has not specified how many extensions a given student would be allowed to file across a degree program.
4. Grace period cut from 60 days to 30 days. After completing your program, you'd have 30 days (not 60) to depart the U.S., transition to another status, begin OPT, or start a new program.
5. Travel during a pending extension would be risky. International travel while an EOS is pending could be treated as abandonment of the application. This would be a meaningful change for students used to traveling on a valid F-1 visa stamp during their studies.
6. Restrictions on changes to academic objectives. The proposed rule would limit certain in-country transfers, restrict moving to a same-level or lower-level program, and cap aggregate ESL study at 24 months. The exact contours of these provisions were among the most contested during public comment and may change in any final version.
7. Earlier accrual of unlawful presence. Once an admit-until date passes without a timely-filed EOS, unlawful presence would begin accruing the next day, the same way it works for B and H visa holders today.

These terms get used interchangeably in casual conversation, and the proposed rule muddies the language further. A quick clarification, because being precise here matters when you're filing forms:

Extension of Stay (EOS) is the new requirement the proposed rule introduces. It's the application you'd file with USCIS, on Form I-539, to extend the admit-until date on your I-94 beyond what was originally granted. This does not exist for F-1 students under current rules because D/S already covers the full program.

Extension of program is what your DSO does in SEVIS today when your I-20 needs to be updated to reflect a longer program length. That's an institutional update, not a federal application. Under the proposed rule, your DSO would still update your I-20, but you would also need to file an EOS with USCIS to extend your I-94. Two separate processes for what is currently one.

Change of Status (COS) is a different process entirely. It's how someone in another visa category (B-1/B-2, H-4, J-1, L-2, and so on) moves into F-1 status without leaving the U.S. The proposed rule does not eliminate COS, but it changes what a successful COS results in. Today, an approved F-1 COS gives you a D/S admission. Under the proposed rule, you'd receive an admit-until date tied to your new I-20.

If you're currently planning a Change of Status to F-1, this last point matters. The COS process itself is not going away, but the document you receive at the end of it would carry an end date you'd have to track and potentially extend.

The honest answer is that the proposed rule affects everyone in F-1 status to some degree. But some students would feel it more than others. Here's how it would play out across the situations EduConnect's students most often find themselves in.

Scenario 1: PhD student in a 5-7 year program

This is the cohort the rule hits hardest. The median time to complete a PhD in the U.S. is 5.7 years, and many programs run longer. Under the proposed rule, every international PhD student would file at least one I-539 to continue their studies past the four-year cap, and many would file two. Whether you finish your dissertation would depend in part on whether USCIS adjudicates your extension on time. USCIS I-539 processing currently runs five to six months on average, and longer in some service centers.

What to do: build extension fees into your funding plan, talk to your DSO about timing, and plan to file your first EOS well before the four-year mark.

Scenario 2: Day 1 CPT master's student

Day 1 CPT programs are typically structured as one to two-year master's degrees, so the four-year cap is not the immediate issue. The bigger consideration is the change in how your I-20 program length and your I-94 admission period interact. Today they're effectively the same thing under D/S. Under the proposed rule, they become two separate timelines, and managing the relationship between them becomes part of maintaining status.

For a student whose STEM OPT is ending and who's enrolling in a Day 1 CPT master's to continue working in the U.S., this matters in a specific way: your current STEM OPT EAD ends on a fixed date, you start your Day 1 CPT program on the new I-20, and the I-94 admit-until date you receive (or are deemed to have, if entering by COS) governs your authorized stay independent of when your CPT actually starts. The Day 1 CPT regulation itself, at 8 CFR 214.2(f)(10), is not changed by the proposed rule. The graduate-program exception that allows DSOs to authorize CPT before the standard one-year wait remains in place. What changes is the structure containing your enrollment.

What to do: if you're using a Day 1 CPT program as a bridge from STEM OPT, work with your DSO and an immigration attorney to map out the date math before you commit. Small misalignments that wouldn't have mattered under D/S can become status problems under fixed dates.

Scenario 3: Change of Status applicant currently in B-1/B-2, H-4, or J-1

If you're filing a COS to F-1 right now, your application would be adjudicated under whatever rules are in effect on the date USCIS decides. If the rule is finalized while your case is pending, the I-94 you receive on approval would likely reflect the new fixed-date structure. This isn't a reason to delay filing, but it is a reason to be precise about your I-20 program end date. Under D/S, a slightly long or imprecise program end date had no material consequence. Under the proposed rule, it determines exactly when your authorized stay ends.

What to do: if you're in the COS pipeline, make sure your I-20 program dates are accurate before you file, and have a working knowledge of what your admit-until date would be under both regimes.

Scenario 4: STEM OPT applicant or current OPT holder

Post-completion OPT and STEM OPT extensions are governed by separate regulations (8 CFR 274a.12 and 8 CFR 214.2(f)(10)) that the proposed rule does not modify. OPT and STEM OPT continue to exist. What changes is the wrapper around them.

Today, when you finish your degree, your D/S admission carries you through your 60-day grace period, your OPT period, and (for eligible STEM graduates) your STEM OPT extension. Under the proposed rule, your I-94 would have an admit-until date that may not align with your OPT or STEM OPT end date, and you'd need to track both.

The 30-day grace period cut is the more immediate operational issue. USCIS OPT processing has been running three to five months. If you're filing 90 days before your program end date (the earliest you can), and adjudication takes four months, your EAD may not be in hand when your grace period ends. Under the current 60-day grace period, this is uncomfortable. Under a 30-day grace period, it's a compliance crisis.

What to do: file OPT as early as you can, the full 90 days before program completion. Don't wait for a job offer to file. You can be on OPT without a job for 90 days, and you cannot start work without an EAD regardless.

Scenario 5: Undergrad finishing a four-year bachelor's on schedule

Realistically, a student who enters as a freshman, follows a four-year track, and graduates on time would not need to file an EOS during their studies. The proposed rule's biggest impact on this student is the 30-day grace period and the new requirement to have OPT or next-step plans locked down before graduation rather than after.

What to do: same as above. File OPT 90 days out. Don't treat the grace period as planning time.

This is where the rule sits today. After the comment period closed in September 2025, DHS has been reviewing comments. Before publication as a final rule, the package goes to the Office of Management and Budget (OMB) for review. The standard implementation period proposed in the NPRM is 60 days from publication of the final rule.

NAFSA's deputy executive director for public policy noted in a recent webinar that the administration has signaled an interest in having the rule in effect for the fall 2026 enrollment cycle. If that's the target and the proposed 60-day implementation window holds, the latest a final rule could be published and still meet that goal would be late spring or early summer 2026. That timeline is not guaranteed. A substantially similar rule was proposed in 2020 and ultimately withdrawn before finalization.

So: it could land soon. It could be modified significantly from the proposed version. It could be delayed or withdrawn. None of these outcomes are knowable today. What is knowable is that "wait and see" is a worse strategy than "prepare for the version that exists, adjust if it changes."

Most of the practical steps you'd take to prepare for an EOS regime are also things you should be doing under D/S. The rule change just raises the stakes of getting them right.

Keep your I-20 accurate. Program end date, major, funding, address. Under D/S, small inaccuracies have been forgivable. Under the proposed rule, your I-20 directly determines your I-94 end date. Audit it now.

Check your I-94 at i94.cbp.dhs.gov. Get in the habit of verifying it after every entry. Under the proposed rule, that page becomes the single most important source of truth about your authorized stay.

Build a financial buffer for I-539 fees. $420 to $470 per filing, plus the possibility of attorney fees. If you're in a multi-year program, budget for at least one filing.

File OPT 90 days out. Don't wait for a job offer. Don't assume USCIS will be fast. The shorter grace period leaves no margin.

Don't travel internationally with a pending extension once the rule takes effect. If you have a planned trip, time it relative to your EOS filing. This is one of the more significant operational changes for students used to traveling freely on F-1.

Talk to your DSO before changing programs, transferring, or switching majors. Several proposed restrictions in this category are still ambiguous, and DSOs will be the first to receive implementation guidance.

If your situation is complex, consult an immigration attorney. Dual-degree students, STEM OPT holders bridging into Day 1 CPT, students mid-transfer, and anyone with a prior status issue should get individual advice before making decisions that lock in dates.

The proposed rule isn't law yet, and it may not become law in exactly the form it was proposed. But the direction of travel is clear enough that the students who will be in the best position when the final rule lands are the ones who started planning under the assumption that it might.

If you're trying to figure out how this affects your specific situation, whether you're in the middle of a Change of Status, considering a Day 1 CPT program after STEM OPT, or just trying to understand what your post-graduation 30 days actually need to look like, the answer depends on the dates on your documents and the exact transition you're navigating. EduConnect works with international students through Alliant University on these pathways, and the team can walk through your specific timeline with you.

The rule is being written. Your plan should already exist.