DHS Proposal Could Reshape F-1 Student Rules: What You Need to Know

The U.S. Department of Homeland Security (DHS) has recently published a proposal that could significantly impact the rights of F-1 international students in the United States. If implemented, these changes would limit educational pathways and post-study opportunities that have long made the U.S. an attractive destination for global talent.

Among the most concerning provisions:

• No Second Master’s Transfers: F-1 students would not be able to transfer their SEVIS record to pursue a second master’s degree.

• Mandatory Higher-Level Progression: Students must move to a higher-level degree (e.g., from master’s to doctorate) if they wish to continue their education.

• Restricted Duration of Stay: DHS proposes to limit how long F-1 students can remain in the U.S. under their visa.

• Shortened OPT Grace Period: The Optional Practical Training (OPT) grace period after graduation would be reduced, potentially cutting opportunities for employment and sponsorship.
  
  

Public Response: Over 13,000 Comments and Strong Opposition

The DHS opened a public comment period to gather feedback on this proposal, set to end on September 29, 2025. As of September 25, more than 13,000 comments had been submitted.

Volume & Sentiment of Comments

• Over 13,000 public comments have already been submitted to the DHS docket in response to the proposal.

• Among them, 91.98% are reported to oppose the changes—reflecting a steep divide against DHS’s proposals.

• Many comments are from individual students or former F-1 visas holders, sharing personal stories about how these changes could derail their academic plans, disrupt career pathways, or force early departures.

• Others are formal submissions from universities, higher education consortia, immigration legal groups, and advocacy organizations, raising technical, legal, compliance, financial, and reputational concerns.

The scale of opposition in such a short window underscores how controversial and high-stakes the proposal is, especially because it touches directly on the core assumptions of how the U.S. has long handled international student status.

Institutional Petitions & Organizational Responses

NAFSA & Coalition Letter to Extend Comment Period

• NAFSA (Association of International Educators) is deeply engaged in the process. They have published resources and guidance to institutions for how to submit comments.

• Together with AILA (American Immigration Lawyers Association) and over 102 other organizations, NAFSA submitted a formal request to DHS to extend the comment period from 30 to 60 days.  

University & Institutional Responses

• Many universities are preparing or already submitting comment letters, citing impacts such as increased compliance burden, advising complexity, risk of enrollment drop, threatening long-term doctoral and research programs, and jeopardizing institutional competitiveness.

• The Yale Office of International Students & Scholars, for example, has published a summary explaining how the fixed-period admission proposal would disrupt how ongoing graduate programs and extensions would work. 

• Several legal firms and immigration policy analysts have commented publicly that the proposal could shift the balance of risk onto students and institutions, introduce uncertainty in extension adjudications, and disincentivize U.S. higher education as a global destination. 

However, even with strong opposition, there is no guarantee that DHS will fully abandon or significantly water down the proposal. The agency could still issue parts of the rule, stagger implementation, or include transition provisions, so it's critical that students, institutions, and advocates remain vigilant throughout the process.

Implementation Timeline

It’s important to note that nothing changes immediately. Here’s the official timeline:

• Feedback period ends: September 29, 2025

• Earliest possible implementation date: October 29, 2025 (30-day notice period after comment closure)

• Realistic outlook: If DHS incorporates revisions or considers feedback, implementation could be delayed well into 2026.

This means students have some time to plan, but also need to remain proactive and flexible in their academic and immigration strategies.

What Students Can Do: Practical Solutions

If you are on OPT or planning your next academic step, here are some strategies to safeguard your future:

Plan A: Apply for a Fall 2025 Intake

• If your master's OPT ends in November 2025 or later, consider applying to another master’s or MBA program that begins in October 2025 or earlier.

• After securing admission, you can defer your start date if needed.

• Confirm enrollment and transfer your SEVIS record before the program’s start date to avoid disruption.

Plan B: Consider a January 2026 Intake

• If DHS delays implementation due to the high volume of feedback, the new rules may not take effect until later in 2026.

• Applying for a January intake gives you time to reassess with your consultant by the end of September and adjust based on updates.

Plan C: Transition to a DBA Program

• Since the proposal requires progression to a higher-level degree, Doctor of Business Administration (DBA) programs remain a safe path forward.

• At universities like Westcliff University, DBA students can choose concentrations that align with both business and STEM career tracks:

  • Non-STEM: Strategic Leadership for the 21st Century

  • STEM: Applied Computer Science, Business Intelligence & Data Analytics, Cybersecurity, IT Management, Web Development & Applications Management

• Pursuing a DBA not only complies with the new rules but also strengthens long-term career prospects.

Reference: Universities provides DBA or other doctoral level Day 1 CPT programs.

If you are unsure which one to choose, you are always welcome to talk with one of our advisors. All of CPTDog's consultation is free to students. 

Stay Informed

We will continue to monitor updates from DHS and the outcomes of the public commenting process. In the meantime, we encourage you to:

📺 Watch our webinar series on the proposed F-1 rules.

💬 Talk to our Consultant to get personal advise on your situation

The future of F-1 visas is at a turning point. While the proposal introduces real challenges, students who prepare early and plan strategically will still find pathways to continue their education and careers in the U.S.