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Breaking News: Major F-1 Visa Reform Enters Final Review Stage — D/S Status May Be Eliminated, Creating New Challenges for International Students
- JC Guedon
- Jul 6
- 5 min read
Translated from Original article in Mandarin: https://mp.weixin.qq.com/s/R9jyFKgRo6zRb8h-ifnlpw
1. Policy Background: From Proposed Rule to Final Rule
The full name of the proposed regulation is "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." It was first released as a Notice of Proposed Rule Making (NPRM) on August 28, 2025, followed by a public comment period that lasted approximately one month.
During that period, numerous stakeholders—including the Association of International Educators (NAFSA), American universities, immigration attorneys, and international students—submitted comments opposing the proposal. Many expressed concerns that the new regulations would create significant administrative burdens and increase uncertainty for international students.
Despite widespread criticism, the proposal has continued moving forward through the federal review process. Once the rule entered review by the Office of Management and Budget (OMB), many immigration experts viewed it as a sign that implementation was becoming increasingly likely. Several immigration consulting firms and international education organizations have predicted that a final version could be published as early as summer 2026, with implementation beginning 30 to 60 days later. Some observers believe the changes could affect students entering U.S. universities as early as the Fall 2026 semester.
2. The Biggest Change: Ending the D/S System
At the heart of the F-1 visa reform which enters its final review stage reform is the elimination of the long-standing "Duration of Status" (D/S) system for F-1 students, J-1 exchange visitors, and certain other visa categories.
Under the current D/S framework, international students may remain in the United States as long as they maintain valid student status. Instead of listing a specific departure date, the I-94 arrival record simply states "D/S." This flexible system allows universities and their Designated School Officials (DSOs) to play a central role in monitoring student status while giving students considerable flexibility throughout their studies.
The proposed rule would fundamentally change this approach.
Instead of receiving D/S status, students would be admitted for a fixed period of time. According to current proposals, most students would be granted admission until the earlier of:
The program completion date, or
Four years after entry into the United States
This means that even if a student's degree program has not been completed, reaching the four-year limit could require the student to proactively apply for an extension of stay. Failure to obtain an extension could result in the loss of lawful immigration status.
3. Extension Applications: More USCIS Involvement
Under the current system, students who need additional time often work directly with their university's international student office to update their I-20.
Under the proposed framework, extending status would become significantly more complicated.
Students would be required to submit a formal Extension of Stay (EOS) application directly to the U.S. Citizenship and Immigration Services (USCIS). Required documentation could include:
Proof of continued enrollment
Financial support documentation
Biometric information
Government filing fees
Additional supporting materials
This shift would likely increase processing times and administrative complexity while introducing the possibility of application denials.
Although many students complete their degrees within four years, not everyone does. Doctoral students, students pursuing dual degrees, those who change majors, or students who encounter personal or academic challenges may need additional time. For these students, extension applications could become an essential part of maintaining legal status.
4. Unlawful Presence: Higher Stakes for Missing Deadlines
Another major change involves how unlawful presence would be calculated.
Under the current D/S system, unlawful presence generally does not begin accumulating immediately when a student's status is questioned. In most cases, a formal determination by USCIS or an immigration judge is required before unlawful presence starts accruing.
The proposed rule would replace that protection with a much stricter timeline.
If a student's authorized stay expires and no valid extension has been approved, unlawful presence could begin accumulating automatically.
The consequences can be severe:
More than 180 days of unlawful presence may trigger a three-year reentry bar.
More than one year of unlawful presence may trigger a ten-year reentry bar.
As a result, international students would need to monitor immigration deadlines much more carefully than under the current system. Missing a filing deadline or misunderstanding one's status could lead to significant long-term immigration consequences.
5. Academic and Career Restrictions
Beyond the elimination of D/S, the proposal includes several additional restrictions that could affect students' academic and professional plans.
Shorter Grace Period
Currently, F-1 students receive a 60-day grace period after graduation or completion of Optional Practical Training (OPT). The proposed rule would reduce this grace period to 30 days.
This change would leave students with less time to:
Apply for a new academic program
Change immigration status
Prepare to leave the United States
Finalize employment plans
Restrictions on Academic Progression
Under the proposal, students who complete one degree in the United States may only continue to a higher academic level.
For example, a student who earns a master's degree would generally be expected to move on to a doctoral program rather than pursue a second master's degree. The stated goal is to prevent students from repeatedly enrolling in equivalent or lower-level programs simply to maintain legal status.
Limits on Changing Majors or Programs
The proposal also seeks to restrict students' ability to change majors, transfer schools, or switch academic programs.
Under the draft framework:
Undergraduate students generally would not be allowed to change majors or transfer schools during their first year.
Graduate students could face restrictions on changing academic fields throughout their degree programs.
For graduate students in particular, this could significantly reduce flexibility. Students who discover new academic interests after enrollment may have fewer options to pivot into a different field.
Language Program Limits
Students enrolled in English-language (ESL) programs could face a maximum participation limit of 24 months.
Potential Changes to OPT
Although the final rule has not yet been released, some policymakers have indicated interest in further restricting work authorization opportunities tied to student status.
As a result, some observers believe future limitations on OPT may be possible, potentially reducing opportunities for international students to gain professional experience in the United States after graduation.
F-1 Visa Reform Enters Final Review Stage: Looking Ahead
Taken together, these proposed changes represent a significant shift in how the U.S. government would regulate international students. The current model of flexible, status-based oversight would be replaced by a system built around fixed admission periods, stricter deadlines, and greater federal oversight.
Jill Allen Murray, Deputy Director of Public Policy at NAFSA, has suggested that the final rule could be released between late May and late June, allowing the government sufficient time to implement the new requirements for students entering the United States in September 2026.
While the exact details remain subject to change until the final rule is published, the overall direction appears clear: international students may face increased administrative requirements, more stringent status-management obligations, and less flexibility in both academic and career planning.
For many international students, the pathway from studying in the United States to gaining work experience and eventually remaining in the country may become increasingly difficult. Careful planning, proactive communication with university international offices, and close attention to immigration developments will be more important than ever.
Editor's Note: The provisions discussed above are based on a proposed rule that has not yet been finalized. Students and families should continue monitoring official announcements from the U.S. government and their institutions for the most up-to-date information.
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