ICE Tightens Scrutiny of Curricular Practical Training for Schools and F-1 Students
In August 2026, the Student and Exchange Visitor Program ("SEVP"), which is administered by U.S. Immigration and Customs Enforcement ("ICE"), published two broadcast messages to Designated School Officials (DSOs) at SEVP-certified schools tightening the agency's posture on Curricular Practical Training ("CPT") for F-1 students. Neither message changes the underlying CPT regulations but both are aimed at deterring issuance of CPT through threats of enforcement and cancellation of SEVP-certification required for schools to enroll foreign students. A small but growing number of universities have already begun pausing certain CPT authorizations in response.
Background
CPT allows F-1 students to participate in practical training such as internships, cooperative education, or practicums, while still enrolled, provided the training is integral to an established curriculum. Under the regulations, CPT is limited to "alternative work/study, internship, cooperative education, or any other type of required internship or practicum," with an exception permitting graduate programs that require immediate participation in practical training to authorize CPT from a student's first academic term, providing the regulatory basis for "Day 1 CPT" programs.
On August 12, 2026, SEVP issued Broadcast Message 2608-01, "Reminder of Liability for DSOs Regarding CPT Authorization." The message states that SEVP has observed a rise in CPT authorizations that do not meet regulatory requirements, specifically, authorizations not constituting an integral part of an established curriculum. SEVP’s announcement that it is increasing scrutiny of CPT approvals reminds DSOs that CPT may be authorized only where the training is integral to an established curriculum and directly related to the student's major, and it requests suspected violations be reported.
On August 24, 2026, SEVP followed up with Broadcast Message 2608-02, "Guidance for Designated School Officials regarding Curricular Practical Training," issued in Q&A format. This second message narrows the interpretation of "integral," indicating that CPT should be authorized only where the practical training is required of all students in the program and the degree cannot be completed without it. SEVP noted that, in the course of investigating schools for compliance, it had found some institutions describing CPT as though it were optional (in the manner of Optional Practical Training) rather than integral, and some institutions were not requiring all students in the same curriculum to complete the training component.
Break from Prior Guidance — But Not a Rule Change
Both messages are explicit that they do not, by themselves, create new legal obligations. The CPT regulation at 8 CFR 214.2(f)(10)(i), including the graduate-studies exception underlying Day 1 CPT, has not been amended, and DHS has separately confirmed in the preamble to its recent Duration of Status final rule that it "does not prohibit or eliminate Day-1 CPT" and "does not make substantive changes to CPT."
However, what has changed is the enforcement posture. SEVP is asking DSOs to authorize CPT only where its absence "would make the attainment of a degree an impossibility" and where the training "is required for all students pursuing that degree." This is more strict than the standard stated in the regulatory text. While the Broadcast Messages expressly disclaim rulemaking force, the gap between the existing regulations and the agency's stated enforcement expectations has prompted some schools to act defensively by discontinuing CPT approvals. This is because DSOs sign each CPT-related Form I-20 under penalty of perjury and improper authorization exposes both the DSO individually and the institution's SEVP certification to risk.
Real-World Impact: Some Universities Pausing CPT Authorizations
As of late August 2026, the number of institutions publicly announcing pauses remains small relative to the thousands of SEVP-certified schools nationwide. Most pauses target a narrow category of CPT for elective, credit-attached arrangements, rather than CPT tied to a published degree requirement required of all students. Schools that have announced changes include:
University of California, Berkeley — Paused authorization of "Course Credit CPT" (the elective course in which a student secures a job and then enrolls in a course to attach academic credit) while continuing to process CPT that is a formal degree requirement required of all students.
University of California, Davis — Similarly paused authorization of Course Credit CPT, while continuing degree requirement CPT.
University of Washington — Paused authorization of any new CPT requests that are not required work experiences for all students in a degree program.
University of Colorado, Boulder — Paused authorization of Course Credit CPT while continuing degree requirement CPT and only for programs where practical training is required for completion of the student's degree or major (not minor).
University of Illinois, Urbana Champaign – Paused Course Credit CPT applications while continuing degree requirement CPT.
University of Southern California - Paused Course Credit CPT applications while continuing degree requirement CPT.
What This Means for Students and Employers
The two broadcast messages may have the impact of making it difficult to employ F-1 students currently enrolled in degree programs under CPT, which many students and employers found attractive as it can be granted directly by the school without having to obtain approval from the immigration authorities. Schools may decide to voluntarily limit CPT approvals by excluding elective or credit-attached CPT, and limit approvals to those training situations that meet the regulatory "integral part of an established curriculum" standard and SEVP's more stringent "required for all students" framing before authorizing new requests.
Although most universities have affirmed that students who have already received CPT authorization would be able to participate in their approved placements this fall, students should obtain confirmation from their DSOs whether their specific CPT authorization is affected before making any employment decisions. Students who seek CPT authorization based on an elective may face challenges from their universities depending on school policy.
We will continue to monitor developments and will provide updates as they become available.