The Student and Exchange Visitor Program (SEVP) has issued two significant updates concerning Curricular Practical Training (CPT), signaling increased scrutiny of when F-1 students may qualify for this type of practical training.
On August 12, 2026, SEVP issued Broadcast Message 2608-01, “Reminder of Liability for DSOs Regarding CPT Authorization.” This was followed on August 24, 2026 by Broadcast Message 2608-02, “Guidance for Designated School Officials regarding Curricular Practical Training.”
Together, the messages provide a considerably narrower interpretation of when practical training qualifies as an “integral part of an established curriculum.” For F-1 students, universities and employers, the guidance could significantly affect internship and employment arrangements that previously qualified for CPT.
What Is Curricular Practical Training?
CPT permits qualifying F-1 students to participate in practical training such as internships, cooperative education and certain work-study arrangements while completing their academic programs.
Federal regulations provide that CPT must be an integral part of an established curriculum and directly related to the student’s major area of study.
Unlike Optional Practical Training (OPT), CPT authorization is generally handled by the student’s Designated School Official (DSO) and reflected in the Student and Exchange Visitor Information System (SEVIS) and on the student’s Form I-20.
SEVP’s existing guidance also provides that a student who accumulates 12 months or more of full-time CPT becomes ineligible for OPT at the same educational level.
What Changed in August 2026?
SEVP stated that it has observed an increase in CPT authorizations that it believes do not satisfy the regulatory requirement that practical training be integral to an established curriculum.
The August 12 message directs DSOs to authorize CPT only when the practical training is genuinely necessary to the academic program. According to SEVP, the training should be sufficiently central to the curriculum that the student could not complete the degree without it.
SEVP also warned schools that CPT should not simply be used to create an employment opportunity for an F-1 student.
The August 24 guidance went further by explaining how SEVP intends to interpret this standard. Most importantly, SEVP stated that where practical training is integral to a particular curriculum, all students participating in that curriculum — international and U.S. students alike — must be required to complete the practical training.
SEVP also indicated that an optional elective generally will not satisfy this standard when the practical-training component itself is optional.
The August 24 guidance also reminded DSOs that cooperative agreements should only be entered into with legitimate, bona fide employers capable of providing a genuine practical training experience. This signals that SEVP intends to look past the paperwork of a cooperative agreement to evaluate whether the employer’s training program is real, not simply whether a curriculum requirement exists on paper.
SEVP has also provided a reporting channel (SEVPFraud@hsi.dhs.gov) for schools and students to report suspected practical training fraud or other instances of schools or students abusing federal regulations.
Why This Matters for Students Using CPT
The new guidance could substantially change how many schools evaluate CPT requests.
Previously, some universities authorized CPT when an internship was connected to an academic course, offered academic credit or otherwise formed part of a student’s academic program even though the internship was not mandatory for every student completing the degree.
SEVP’s August guidance takes a more restrictive position.
Under the agency’s current interpretation, students and schools should expect closer examination of questions such as:
- Is the practical training actually required to complete the degree or curriculum?
- Is the requirement documented in the school’s academic program?
- Is practical training required for every student enrolled in that curriculum, regardless of immigration status or citizenship?
- Is the training directly related to the student’s major field of study?
- Would the student still be able to complete the degree without participating in the practical training?
Some universities have already responded by restricting or temporarily pausing CPT authorizations that do not satisfy the new interpretation. For example, several university international student offices have announced that CPT may currently be approved only where practical training is an established degree requirement.
What About “Day 1 CPT”?
The guidance is particularly important for students enrolled in programs commonly described as offering Day 1 CPT.
CPT has not been eliminated, and SEVP has not issued a regulation expressly prohibiting CPT beginning in a student’s first academic term. Indeed, existing ICE guidance recognizes that a graduate student may potentially receive CPT authorization during the first semester when the student’s program requires that practical experience.
However, the August 2026 guidance makes the underlying academic requirement far more important. A program should not assume that CPT is permissible merely because an internship course is available or because employment can be incorporated into the student’s studies. Under SEVP’s current position, the practical training must actually satisfy the agency’s interpretation of an integral curricular requirement.
As a result, programs relying heavily on optional or employment-driven CPT arrangements may face substantially greater scrutiny.
Greater Responsibility for DSOs and Schools
SEVP’s guidance also puts considerable emphasis on the responsibilities of Designated School Officials.
When authorizing CPT, DSOs must determine that the training satisfies the applicable regulatory requirements and properly document the authorization in SEVIS.
SEVP warned that it may request documentation demonstrating why a particular CPT placement qualifies as an essential component of the student’s curriculum. The agency further stated that improper CPT authorization could have consequences for both schools and individual school officials, including possible action affecting a school’s SEVP certification.
As noted above, SEVP has also identified a reporting channel through which suspected practical training fraud or regulatory abuse can be brought to the agency’s attention, adding another avenue for CPT concerns to reach SEVP directly.
Universities therefore may become more conservative when evaluating CPT applications while they review their academic catalogs, degree requirements and internal authorization procedures.
What Should F-1 Students Do?
F-1 students who are considering CPT should not assume that a previously accepted internship arrangement will automatically qualify under the new guidance.
Before beginning employment, students should work closely with their DSO and confirm that CPT has been properly authorized in SEVIS and reflected on an updated Form I-20.
Students may also want to determine:
- Whether practical training is formally required for their degree or academic track;
- Where that requirement appears in the university’s academic materials;
- Whether all students in the same curriculum must complete the practical-training requirement;
- Whether the proposed employment is directly related to their major; and
- Whether their school has changed its CPT policies following the August 2026 guidance.
A student should not begin CPT employment until the required DSO authorization is in place. ICE specifically advises that working before CPT authorization may violate F-1 status.
Employers Should Review CPT Arrangements Carefully
Employers that hire F-1 students through CPT should also pay attention to these developments.
A CPT authorization is tied to a specific practical-training arrangement and employer. Employers should make sure the student’s authorization covers the correct employer, dates and training activity.
Because SEVP has signaled that it intends to look past paperwork and evaluate whether a cooperative agreement reflects a genuine training relationship, employers should be prepared to show that a CPT placement is real training rather than a way to staff a regular position. Requesting written confirmation from the DSO that the placement is a required, integral part of the student’s academic program can help employers document that the arrangement is properly authorized.
Companies that regularly employ students through CPT — particularly students participating in programs offering practical training early in the academic program — may also want to review their procedures and coordinate with immigration counsel when questions arise.
The key issue is no longer simply whether the job relates to the student’s degree. The student’s academic program and the basis upon which the school authorized CPT may become increasingly important.
CPT Has Not Disappeared — But the Rules Are Being Applied More Narrowly
The August 2026 SEVP messages do not eliminate CPT and do not themselves replace the existing federal CPT regulation. They follow a similar pattern to SEVP’s earlier warning on STEM OPT employer fraud, part of a broader trend of heightened scrutiny across F-1 practical training programs.
They do, however, demonstrate a clear enforcement shift. SEVP is now taking a substantially narrower view of when practical training constitutes an integral part of an established curriculum, while simultaneously warning schools and DSOs that CPT authorization will receive greater scrutiny.
Students, universities and employers should therefore review CPT arrangements carefully rather than relying on how similar cases may have been handled in previous academic years.
Frequently Asked Questions
Has CPT been eliminated?
No. SEVP has not issued a regulation eliminating CPT or Day 1 CPT. What changed is how SEVP interprets and enforces the existing requirement that CPT be integral to an established curriculum, which in practice narrows which programs and placements will qualify.
Does this affect students who already have CPT authorization?
The guidance is directed at how DSOs authorize CPT going forward, and some schools have already begun reassessing existing arrangements. Students with current CPT authorization should confirm with their DSO whether their program’s basis for authorization is affected.
Why does it matter whether U.S. students take the same course?
SEVP has indicated that if a curriculum genuinely requires practical training, that requirement must apply to all students in it, not only international students. A course where only F-1 students routinely choose the internship option, while domestic students opt for an alternative, is unlikely to satisfy SEVP’s interpretation of an integral requirement.
Is there a way to report suspected CPT abuse to SEVP?
Yes. SEVP has identified a reporting channel (SEVPFraud@hsi.dhs.gov) for schools and students to report suspected practical training fraud or other regulatory violations. Schools should expect DSOs to apply the new interpretation more cautiously and should review internal approval processes accordingly.
What should an employer do if a school pauses or denies a CPT authorization?
Employers should confirm directly with the DSO whether the placement can be documented as an integral, required part of the student’s curriculum and whether the cooperative arrangement itself meets the school’s updated standards. Employers with recurring CPT hiring should consider coordinating with immigration counsel before relying on a placement that has not been clearly authorized.
NPZ Law Group will continue monitoring SEVP and DHS developments affecting F-1 students and practical training programs. If you or your family members have questions about how this or other immigration and nationality matters may affect you, please do not hesitate to contact the immigration and nationality lawyers at NPZ Law Group. You can reach us by emailing info@visaserve.com or by visiting our website at www.visaserve.com for more information.