US OPT Fee Proposal Moves Closer to Reality

A potentially dramatic change is moving through the U.S. immigration rulemaking system—and Indian students are watching closely.

The U.S. Department of Homeland Security (DHS), through U.S. Immigration and Customs Enforcement (ICE), has been developing a proposal that could introduce a new fee for Optional Practical Training (OPT), the post-study work programme used by eligible international students on F-1 visas.

The proposal has now completed review by the White House’s Office of Information and Regulatory Affairs (OIRA).

But there is a very important line between “moving closer” and “becoming law.”

The proposed fee is not currently payable.

And despite widespread reporting about a possible $100,000 charge, the official regulatory record does not yet confirm that amount. The OIRA record identifies the proposal as “Optional Practical Training Fees”, submitted by ICE on August 20 and reviewed on September 11, but it does not disclose the proposed fee amount or who would be responsible for paying it.

For Indian students, that distinction is critical.

What exactly is OPT?

Optional Practical Training allows eligible F-1 international students to obtain temporary employment authorisation for work directly related to their field of study.

A student generally may receive up to 12 months of post-completion OPT.

Students who qualify for the STEM extension can potentially receive an additional 24 months, allowing as much as three years of practical training in total.

For many international students, this period is much more than a line on an immigration form.

It is the bridge between:

University → first U.S. job → professional experience → possible longer-term employment sponsorship.

For Indian students in particular, that bridge can be important because many pursue U.S. graduate degrees in technology, engineering, data science, computer science, business analytics and other fields where OPT can provide the opportunity to gain U.S. work experience.

So when a possible six-figure fee enters the conversation, students understandably pay attention.

Very close attention.

Where does the $100,000 figure come from?

This is where DOONITED readers need to be careful.

The $100,000 figure has been widely reported as the amount the administration was considering, but it is not currently confirmed in published official rule text.

The DHS/ICE proposal went to OIRA on August 20, 2026, and OIRA completed its review on September 11. The proposal’s official record does not currently reveal:

• the final proposed fee amount;
• who would pay it;
• which OPT applicants would be covered;
• whether existing OPT holders would be affected;
• whether STEM OPT extensions would be treated differently; or
• what exemptions or transition arrangements might apply.

That means headlines saying “US has imposed a $100,000 OPT fee” are currently inaccurate.

There is no such fee in effect today.

OIRA review is not the finish line

The September 11 development is significant because the proposal has passed through an important stage of the federal regulatory process.

But it is still a proposed rule.

The next major step is publication in the Federal Register as a Notice of Proposed Rulemaking (NPRM).

That publication should provide the details that students currently do not have.

Once an NPRM is published, the public normally receives an opportunity to submit comments before the agency considers issuing a final rule.

Only after the rulemaking process is completed and a final rule becomes effective could a new mandatory OPT fee actually apply.

So the sequence is broadly:

DHS/ICE proposal → OIRA review → Federal Register NPRM → public comments → agency review → final rule → effective date.

The current development is therefore important.

But it is not an invoice.

What Indian students should do today

The practical answer is surprisingly simple:

Don’t pay a $100,000 fee.

There is no such OPT fee currently in effect.

Students should continue following the existing OPT procedures and applicable USCIS requirements.

Business Standard likewise reports that eligible students can continue using the current OPT system and that existing filing fees remain applicable while the proposed fee has not yet been implemented.

Students approaching graduation should therefore not cancel OPT plans solely because of headlines about the proposed fee.

At the same time, they should not ignore the development.

Both extremes would be unhelpful.

Why Indian students are particularly interested

India is one of the largest sources of international students in the United States.

For many Indian students, the U.S. education journey involves considerable financial investment.

Tuition.

Accommodation.

Health insurance.

Living expenses.

Travel.

And then the job search.

OPT can provide the opportunity to recover some of that investment through authorised employment while gaining professional experience.

A very large additional fee could therefore fundamentally change the economics of the decision—but whether it would actually do so depends on the final rule, including who would pay the fee.

And that last point is currently unanswered.

Would the student pay?

Would an employer pay?

Would universities become responsible in some circumstances?

Would different categories face different charges?

The public does not yet have the official answers.

The employer question could be crucial

The reported $100,000 figure naturally creates one immediate reaction:

“Which student can afford that?”

But the more important question may be:

“Who would legally be required to pay it?”

The publicly available regulatory information does not yet answer that question.

That distinction could dramatically change the practical impact.

If students were required to pay a six-figure amount, the barrier would be enormous for many recent graduates.

If employers were responsible, the consequences could instead appear in hiring decisions, salary negotiations or employer willingness to recruit international graduates.

If universities were involved, the financial effect could reach international enrolment and institutional budgets.

Therefore, the headline number alone does not tell us the real economic impact.

The bigger issue: what happens to the student-to-worker pathway?

OPT has long occupied an unusual position in the American immigration system.

It is technically temporary work authorisation connected to F-1 study.

But in practice, it can become an important period during which graduates establish themselves professionally and employers evaluate their skills.

For STEM graduates, the additional 24-month extension can provide a much longer period of work experience.

That creates a pathway:

Study → OPT → STEM OPT, where eligible → possible employer sponsorship.

A major additional fee could alter that pathway.

But again, this is a potential consequence of a proposal—not a current legal fact.

The DOONITED Editorial View

The most important thing missing from the current debate is often precision.

A reported $100,000 figure is dramatic.

It produces excellent headlines.

It also produces excellent WhatsApp forwards.

But immigration policy is decided by legal text, not WhatsApp enthusiasm.

At present, the official regulatory record tells us that DHS/ICE has proposed new OPT fees and that the proposal has completed OIRA review. It does not yet establish that every OPT applicant will face a $100,000 charge.

That distinction matters enormously for students making decisions worth tens of thousands of dollars.

There is also a broader policy question.

The U.S. government can legitimately review the costs, administration and oversight of OPT. It can also seek to address fraud, programme integrity and labour-market concerns.

But if a proposed fee becomes so large that it fundamentally changes access to post-study employment, the government would need to consider the consequences for universities, employers, students and the U.S. talent pipeline.

A policy intended to control a programme can also change the programme’s economic function.

That is why the final regulatory details matter more than the rumoured number.

What happens next?

For Indian students, there are several dates and developments worth watching.

1. Federal Register publication

This is the next major public milestone.

The proposed rule should provide the formal details.

2. Public comment

Once an NPRM is published, affected students, universities, employers and other stakeholders can examine the proposal and submit comments.

3. Final rule

DHS would then have to consider the comments and decide whether and how to proceed.

4. Effective date

Even a final rule does not necessarily mean the fee becomes payable immediately. The final rule should specify its effective date and transition arrangements.

5. Possible litigation

If the final rule is challenged, courts could become involved.

That is not unusual in major U.S. immigration policy changes.

What students should do now

There is no need for dramatic action based solely on the $100,000 reports.

Instead:

Continue following current OPT procedures.

Check USCIS information rather than social-media rumours.

Stay in contact with your university’s international student office and Designated School Official.

If you are close to graduation, do not miss existing OPT filing deadlines because of a proposal that has not yet become effective.

And perhaps most importantly:

Do not assume that the reported $100,000 amount is final.

It isn’t officially confirmed yet.

A potentially important moment for Indian students

The OPT proposal is nevertheless worth watching closely.

Indian students have invested heavily in U.S. higher education, and OPT can provide a valuable opportunity to convert that education into professional experience.

A major new fee could affect that calculation.

But today’s situation is more accurately described as:

The proposal has moved forward. The fee has not.

That is the fact students need to remember.

Washington has moved the paperwork one step closer to the public.

The public still has not seen the final price tag.

And until the actual proposed rule is published, nobody should pretend that the number on the headline is the number on the law.

For Indian students planning their U.S. education and career, that distinction could be worth far more than $100,000.