If you are a Day 1 CPT student, or you are considering enrolling in a graduate program that offers Day 1 CPT, the most consequential immigration story of the past year is not about CPT itself. It is about Duration of Status.

In August 2025, the Department of Homeland Security published a proposed rule that would eliminate Duration of Status for F, J, and I visa holders and replace it with a fixed admission period. Public comment closed at the end of September 2025. As of this writing, the rule has not been finalized, but the academic compliance community is preparing as if some version of it will move forward.

This guide explains what Duration of Status currently means for F-1 students, what the proposed rule would change, and how those changes interact specifically with Day 1 CPT enrollment. It is written as a reference. It is not legal advice, for individual situations, consult your Designated School Official (DSO) and a qualified immigration attorney.

When you are admitted to the United States on an F-1 visa, U.S. Customs and Border Protection issues an I-94 record marked "D/S" - Duration of Status. Unlike most non-immigrant visa categories, F-1 admission has historically not carried a fixed expiration date.

Duration of Status does three things that matter:

It ties your authorized stay to your program, not the calendar. As long as you maintain F-1 status, full-time enrollment, valid I-20, valid work authorization for any employment, you are lawfully present. Program extensions are handled by your DSO at the school level.

It keeps program changes administratively simple. Extending an I-20, transferring schools after one academic year, or progressing to a higher level of study generally does not require a USCIS filing. Your DSO updates SEVIS, and your status follows.

It limits when unlawful presence begins to accrue. Under current policy, unlawful presence for D/S admittees does not start the day a status problem occurs. It starts only when USCIS formally finds a status violation in the course of adjudicating a request, or when an immigration judge orders removal. That distinction is critical for the 3-year and 10-year reentry bars under INA 212(a)(9)(B).

For Day 1 CPT students specifically, Duration of Status is the structure that makes the entire program work cleanly. You enroll, your I-20 is issued for the full program length, you begin authorized employment under CPT, and your lawful status is maintained as long as you continue to meet program requirements.

The August 2025 proposed rule would replace Duration of Status with a fixed admission period for F, J, and I visa holders. The core changes:

Fixed admit-until date. Instead of "D/S," the I-94 would carry an actual expiration date, the earlier of the I-20 program end date or four years from the date of admission, whichever is sooner.

Mandatory Extension of Stay filings. Students whose programs run past their admit-until date would need to file Form I-539 with USCIS to request an Extension of Stay (EOS) before that date. This means a filing fee, biometrics, and a wait for adjudication, replacing what is currently a DSO-level update.

Shortened grace period. The post-completion grace period would drop from 60 days to 30 days. This is the window in which a student must depart the U.S., transition to another status, secure approved Optional Practical Training, or begin a new program.

Travel restrictions during pending EOS. International travel while an Extension of Stay application is pending could be treated as abandonment of that application, a major change for students used to traveling freely on a valid F-1 visa stamp.

Limits on school transfers. Transfers within the first academic year would generally not be permitted absent SEVP authorization.

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, H, and most other visa categories.

The rule has not been finalized. As of late April 2026, F-1 students are still admitted for Duration of Status, and the I-94 still reads "D/S." Nothing in the proposal is currently in effect.

The proposed rule does not change CPT regulations. Curricular Practical Training is governed by 8 CFR 214.2(f)(10), and the proposal leaves that section untouched. The graduate-program exception that allows DSOs to authorize CPT before the standard one-year wait, the regulatory basis for Day 1 CPT, remains in place.

What changes is the structure that contains your enrollment. Day 1 CPT students now operate under a system where the I-20 program length and the I-94 admission period are effectively the same thing. Under the proposed rule, those become two separate documents with separate timelines, and managing the relationship between them becomes part of what it takes to maintain status.

The students most affected are the ones in transition between immigration scenarios, and Day 1 CPT students are disproportionately in those scenarios. Several specific cases:

Bridging from STEM OPT to a new graduate program:

Students whose STEM OPT extension is ending often enroll in a Day 1 CPT master's program to continue working in the U.S. while pursuing additional graduate credentials. Under the current framework, the new I-20 establishes Duration of Status that runs through the end of the new program.

Under the proposed rule, the new admit-until date resets to the new I-20 end date, which works the same way in practice for programs under four years. The risk is administrative: with more formal review built into every transition, there is less margin for error if a filing is mistimed or a SEVIS record is updated incorrectly.

Change of Status from H-1B to F-1:

After a layoff, some H-1B workers pursue a Change of Status to F-1, often into a Day 1 CPT program, to maintain lawful status and continue working under CPT authorization. The H-1B grace period is 60 days. An I-539 Change of Status filing has its own processing timeline.

Under the proposed rule, the same student may need to file additional Extension of Stay applications later if the new program runs long, stacking USCIS adjudications on top of one another. Cushion that already feels thin gets thinner. This is the scenario where filing early and documenting carefully matters most.

Change of Status from J-1 to F-1:

J-1 students pursuing a Change of Status to F-1, particularly those subject to the two-year home residency requirement who have received a waiver, face similar timing pressure. Day 1 CPT programs are commonly used as the destination, and the proposed rule increases the importance of clean transitions and timely filings.

PhDs and longer programs:

Doctoral students are the group most clearly affected. A program that runs five to seven years would require at least one Extension of Stay filing mid-program. Missing the admit-until date, even briefly, would begin the unlawful presence clock. For Day 1 CPT students in research-track programs, this is a meaningful operational change.

Stacked Master's programs:

Enrolling in a second master's program after the first, already an area of close scrutiny at H-1B time, would face a second layer of review under the proposed rule: both the academic justification for the second program and the formal admission timeline. Documentation of academic progression becomes more important, not less.

A few claims circulating online warrant correction:

Day 1 CPT is not being eliminated. The proposed rule does not modify CPT regulations. Eligible graduate students at SEVP-certified institutions remain authorized to receive Day 1 CPT under existing rules.

The rule is not retroactive in its proposed form. Students currently admitted for Duration of Status would receive transition treatment. The exact mechanics of the transition provisions were among the most-contested elements during public comment and may change in any final version.

Nothing has changed yet. F-1 students arriving in 2026 are still admitted for D/S. I-94 records still read "D/S." Any source telling you otherwise is either misinformed or describing a future state as current fact.

This is the second time this rule has been proposed. A substantially similar version was published in 2020 and withdrawn before finalization. The current proposal incorporates feedback from that earlier process.

Does the proposed rule make Day 1 CPT illegal?

No. The proposed rule addresses the period of authorized admission for F, J, and I visa holders. It does not modify the regulations governing Curricular Practical Training, including the graduate-program exception that authorizes Day 1 CPT.

When does the new rule take effect?

It has not taken effect. As of this writing, the rule is in the post-comment phase of federal rulemaking. There is no fixed timeline for finalization, and the final version may differ from what was proposed.

Will current F-1 students keep Duration of Status?

The proposed rule includes transition provisions for currently enrolled students. The specifics of those provisions were among the elements most contested during public comment and could change before any final rule is published.

What is an "admit-until date"?

Under the proposed rule, the admit-until date would replace "D/S" on the I-94 record. It would be set as the earlier of the I-20 program end date or four years from the date of admission to the U.S.

How does Duration of Status interact with the Change of Status process?

A successful Change of Status to F-1 results in a new I-94 record reflecting F-1 status. Under current rules, that record carries D/S. Under the proposed rule, it would carry an admit-until date tied to the new I-20.

Where can I read the proposed rule?

The rule was published in the Federal Register in August 2025 under the title concerning Establishing a Fixed Time Period of Admission for nonimmigrant academic students. NAFSA also maintains a public summary and analysis.

EduConnect USA partners with Alliant University's School of Management and Leadership to enroll international graduate students in Day 1 CPT eligible programs. We support students through the enrollment process, I-20 issuance, F-1 visa pathway questions, and Change of Status filings from H-1B, J-1, or other categories. For students pursuing a Change of Status to F-1, our enrollment team can advise on timing and program selection.