Northwestern has tightened its CPT criteria after federal officials narrowed how schools may approve the work authorization, leaving international students looking for clarity about internships and practical training. The new test reaches beyond whether a placement relates to a student's major.
Background: New DHS/SEVP Memo of August 24, 2026 Tightens Curricular Practical Training Rules for International Students
SEVP’s August 12, 2026 and August 24 directives warn school officials about CPT approvals and define when training counts as part of a curriculum. The university’s international student office updated its CPT page on 09/29/2026 to say the training must be required for all students in the curriculum.
The agency has not changed the underlying regulation. But its interpretation is prompting universities to review eligibility, and four higher-education groups have asked a federal court to block the shift.
Students still face the school-by-school review. A hearing on the legal challenge is scheduled for November 6.
The new test ties CPT to a requirement shared by every student
SEVP, the U.S. Immigration and Customs Enforcement program overseeing F-1 students, issued its first August message on August 12, 2026. It cautioned designated school officials, or DSOs, about improper CPT approvals and potential liability, citing what the agency described as a rise in authorizations that failed to meet the rules. The concern centered on training that was not genuinely part of an established curriculum.
A second message, Broadcast Message 2608-02, followed on August 24, 2026. It said practical training must be integral and required for every student in a program, rather than available through optional internship credit or professional experience. The regulation, 8 C.F.R. 214.2(f)(10)(i), remains unchanged; SEVP says it is applying a narrower reading of its existing language.
Under that reading, an elective course cannot support CPT, even if the course counts toward a degree. A program also cannot offer international students a CPT route that domestic classmates may skip. And a student cannot qualify if another course or option lets them finish the degree without practical training.
The University of Wisconsin–Madison said its SEVP representative clarified in writing on August 27, 2026, that experiential learning must be an express requirement for every student in the program of admission. Prior approvals do not guarantee future eligibility. Stony Brook University’s Visa and Immigration Services warned that earlier decisions do not establish ongoing eligibility under the new guidance.
DSOs must document that a placement is required by the curriculum and connected to the student's major. SEVP warned that officials who fail to do so could face sanctions. The agency also reminded schools to make cooperative agreements only with legitimate employers able to provide quality training.
SEVP opened a confidential reporting channel, SEVPFraud@hsi.dhs.gov, for DSOs who say school leaders are pressuring them to approve CPT that does not meet federal requirements. Complaints go to SEVP and Homeland Security Investigations for review.
Campus criteria preserve other limits on work and enrollment
The university’s criteria retain several requirements alongside the new curriculum-wide test. CPT must relate directly to a student's major, and a student must be in good academic standing. Work may be paid or unpaid, but students on academic probation cannot participate.
Students generally must first complete one full academic year at an SEVP-approved U.S. higher education institution. The university counts that as 3 quarters, 2 semesters or 3 trimesters. A graduate student may qualify earlier if the program requires an internship during the first academic year.
Students must register for an academic course tied to the internship. If the placement falls during the academic year, they must take the relevant course in that term. For summer work, enrollment may be in the summer term or the following Fall term.
CPT can be part-time, at 20 hours/week or less, or full-time, over 20 hours/week. But 12 months or more of full-time CPT makes a student ineligible for post-completion OPT. Students cannot be self-employed under CPT, including for startup activity; that work requires pre-completion OPT authorization from USCIS.
The school permits CPT for remote work performed inside the United States for U.S. or international employers, but not for work performed outside the country. A student has authorization only after receiving an updated I-20 listing the CPT approval. Working before that authorization can violate F-1 status.
Fully funded TGS students who remain funded during CPT may work no more than 20 hours/week across all roles under TGS policy. They must request Permission to Work for additional opportunities. The university says students who have completed all required experiential learning cannot receive further CPT, and may consider pre-completion OPT for other employment.
Four education groups want the judge to pause the federal shift
NAFSA: Association of International Educators, the Association of American Universities, the Presidents' Alliance on Higher Education and Immigration, and the Association of Independent Colleges and Universities in Massachusetts filed a complaint and motion for a preliminary injunction on October 5, 2026. They brought the case in the U.S. District Court for the District of Massachusetts.
The organizations argue the government introduced its interpretation without substantive explanation, public comment or recognition that it departed from the prior approach. They say the messages expose DSOs to severe institutional penalties and potential personal liability for practices the government had long permitted, while disrupting plans made by students and schools.
“Changing how CPT is administered through broadcast messages, without formal rulemaking, is an aberration that must be challenged,” NAFSA Executive Director and CEO Fanta Aw said. She said the new restrictions put DSOs in an untenable position without the clarity and due process that formal rulemaking provides.
The plaintiffs ask the court to restore the previous framework, shield students and institutions from retroactive penalties, and preserve access to academically meaningful training. The judge is set to hear arguments on the preliminary injunction request and a stay of agency action on November 6. No injunction has been described in the material as having been issued in this case.
Other universities have tightened review as students weigh alternatives
Schools have responded with pauses and more demanding reviews. UCLA and UC Berkeley paused some CPT work authorization applications while assessing the new guidance, and Boston University said the narrowed eligibility standards led it to pause certain approvals.
At Wisconsin, the international student office said it would not retroactively cancel CPT approved before August 24, 2026, because those cases were reviewed under the rules and policy guidance then in place. Students must provide published program evidence that practical training is mandatory for everyone in their degree program.
Stony Brook said it would assess each application against the student's curriculum and may seek additional documentation from an academic department when published program materials do not clearly establish a training requirement. University of Connecticut international student services director Arthur Galinat wrote on September 10, 2026, that the office could not approve CPT unless the internship was required for all students in the degree program. Students may still submit applications through its portal, but approval is not assured.
Students whose programs do not meet the new standard can pursue pre-completion OPT instead. That route requires an application to the school's international office, followed by Form I-765 and the applicable USCIS filing fee. Work cannot begin until USCIS approves the application and issues an Employment Authorization Document.
CPT itself is authorized by the school's DSO, not USCIS. Students generally do not file Form I-765 or wait for an employment card for CPT; the school updates SEVIS and issues an I-20 showing the employer, work location, dates and whether the job is part-time or full-time. For Form I-9, USCIS lists an unexpired foreign passport, an F-1 Form I-94 and an endorsed I-20 together as a List A document combination showing identity and employment authorization.
The August interpretation also makes Day 1 CPT harder to support, though it does not ban the practice. A legal analysis by MeltzerHellrung said programs built around immediate practical training, including some STEM and business master's programs, may need to reassess current approvals and consider pausing new ones.
Manifest immigration attorney Ana Gabriela Urizar advised students and employers to confirm the curriculum connection before accepting or offering a position:
“My advice to both sides is the same: get it in writing early. Employers should ask the DSO directly whether the position ties to a required part of the curriculum, not just the student's major, and keep that confirmation on file. Students should do the same with their academic advisor before they accept an offer, not after.”
