Loss of D/S Rule

17 July 2026

The pending “Loss of D/S Rule” has been finalized, and has been published in the Federal Register today - July 17, 2026. This means the effective date of the rule will be September 15, 2026.  After an initial scan, It is largely similar to the proposed rule, keeping most of the main provisions, including:

• Setting a date-certain end date for all new F and J admissions

• Requiring F and J’s to apply for extensions through the filing of an I-539 form with USCIS, including an updated extended I-20 form or DS-2019 form from the DSO or ARO. Alternatively, extensions can be processed through CBP, requiring travel and re-entry with an updated I-20 or DS-2019 form

• Requiring those applying for OPT or STEM OPT to also file for an extension with USCIS

• Allowing F and J’s currently in the U.S. an admission until their current I-20 or DS-2019 end date, up to a maximum of four years in the future

• F-1s currently in the US and filing for OPT within 6 months of the effective date of the rule will not need to file a USCIS extension application

• Restricting undergraduates from transferring out in the first year of study

• Restrict graduate students from making any changes to their academic programs, and from transferring schools.

• Prohibiting a move to a new degree at the same or lower level after completion of one degree

• Limiting ESL students to a 24 month program

Find the pdf of the rule here .

Lots to unpack! We will be taking a deeper dive into the content of rule, and will provide a more detailed update soon.  Remember - the rule is not in effect immediately.  There is a 60-day grace period, with an effective date of September 15, 2026. The rule is subject to the Congressional Review Act (CRA), however, so there is a chance the effective date might be pushed back, if Congress has issues with the rule.

We may expect legal challenges to the rule as well. 

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