8 September 2026
CPT – Background
Curricular Practical Training (CPT) is allowed under F-1 regulations (8 CFR 214.2(f)(10)(i)). Students in F-1 status may accept curriculum related training that is defined as “alternative work/study, internship, cooperative education or any other type of required internship or practicum that is offered by sponsoring employers through cooperative agreements with the school.” ((8 CFR 214.2(f)(10)(i))
The internship or training experience must be related to the student’s major program, and be “integral” to the established curriculum.
Prior to a broadcast message issued on August 12, 2026 (see Appendix A), the regulatory interpretation accepted by SEVP credit-bearing internship experience related
allowed CPT to be approved for any to the academic major, or any experience required of all students in the program in order to meet graduation requirements. This is supported in previous documents and memos, including the Practical Training Fact Sheet (2019).
In addition – the previously available SEVP regarding CPT:
Topic 1: Basic Guidelines for CPT
CPT is only available to F-1 students curriculum. In practical terms, an opportunity must be required by mustreceivecreditforthetraining.
DSO training included this information
when it is an integral part of an established part of an established curriculum” means curriculum or,ifnotrequired,thestudent
Change in SEVP interpretations of the CPT regulations
The two memos issued by SEVP in August of 2026 (see Appendices A and B) set forth significant changes in how the regulation is now being interpreted by SEVP.
First – they define a far narrower definition of “integral” to mean required – without which, the student would not be able to graduate and receive the degree. This removes the option for CPT required by a course, related to the academic major and taken for academic credit, if it is not required for graduation. Second – they state that a signed cooperative agreement between the employer offering the internship experience, and the school, is required in order for an internship offer to meet the CPT eligibility requirements.
Confusingly, as of September 7, the SEVP Study in the States website states that “CPT requires a signed cooperative agreement or letter from the employer .” (https://studyinthestates.dhs.gov/sevis-help-hub/student-records/fm-student-employmen t/f-1-curricular-practical-training-cpt)
This is also stated on the ICE website: “CPT
requires a signed cooperative agreement or a letter from your employer .” (https://www.ice.gov/sevis/practical-training)
DSO / Institutional Liability
The August 12 memo explicitly states that DSOs and institutions may be held liable for improper CPT usage.
Potential liability: Improper CPT authorization, such as for non-integral purposes, may subject both the institution and individual DSO to administrative or legal consequences. This includes withdrawal of SEVP certification and potential penalties for providing false information or misrepresenting the nature of the training. (Broadcast Message 2608-01)
This language is of great concern to DSO’s and schools alike. Many institutions are changing the eligibility criteria for CPT to match the more restrictive interpretation found in these two memos – although it is critical to remember that the regulatory language has not changed.
New policy limits on CPT
Many schools now are implementing policies that only allow CPT for programs that show the work experience as a graduation requirement for all students enrolled in the program. Some schools will now only approve CPT if there is a signed contract (cooperative agreement) between the school and the employer. International students who may be affected by these changes should discuss any plans for CPT with their academic departments AND their DSO immigration advisor. CPT FAQs:
QUESTION :I am in a doctoral program and credit to complete necessary research on
am enrolling in a thesis research course for thesis. I have been offered an internship with a Genetics research company and would have access to a large data set that is directly related to my dissertation topic. Would this course meet the requirements for CPT under this new interpretation?
ANSWER : This will depend on your school’s will agree to sign a cooperative agreement,
CPT policies. If the employer and school and if the research course is required by your academic program, and explicitly requires an internship experience, then it may comply with SEVP’s new interpretation regarding CPT definitions and requirements.
QUESTION: I am a nursing student with required clinical rotations at a local hospital. Can I continue in this major? I can’t graduate without completing these rotations.
ANSWER: Assuming the hospital and school have a signed cooperative agreement, CPT should be approvable in this scenario because the rotations are a degree requirement for all students in the program and not elective.
QUESTION : I completed an internship under a CPT authorization last year. I was enrolled in a course for academic credit, and it did require the work experience, but there was no signed agreement between my school and the employer. Will I be considered to have lost my legal status because I participated in this internship?
ANSWER : This is uncertain – though under above), your participation would have been your school’s DSO, and consider consulting
QUESTION : I am a music student, and we
SEVP’s previous interpretations (listed compliant. We recommend you consult with with an immigration attorney as well.
required, as a condition of graduation, to do 50 hours of paid internships involving concerts and performances. Will we be able to continue to be approved for CPT for these “gigs”?
ANSWER : It is helpful that the performances are required for graduation. Ultimately this will depend on your school’s interpretations of the new policy memos, and whether or not they will require signed cooperative agreements from your host organizations, or whether they will accept just an internship offer letter. Consult with your academic department and your DSO. QUESTION: My department offers three different plans for an MBA degree – one plan is research-based, one plan is internship-based and one plan is study abroad-based. Within the internship plan, an internship is required for degree completion. If I were enrolled in the internship plan, would I be eligible for CPT?
ANSWER: Ultimately this will depend on your school’s interpretations of the new SEVP policy memos, but there is a strong case that since an internship is required for degree completion under this curriculum, CPT should be authorizable.
QUESTION : My degree program doesn’t have an internship requirement but I really want to get practical training in my field before I graduate. Do I have any options?
ANSWER : Yes. While CPT may not be possible according to new SEVP’s interpretation, know that there are still options for you to pursue experiential learning opportunities during your academic program. Some options to explore with your school include on-campus internships, traditional unpaid internships with nonprofit organizations, internships abroad, and planning ahead to apply for Pre-Completion OPT.
Appendix A: Broadcast Message 2608-01
Broadcast Message: Reminder of Liability for DSOs Regarding CPT Authorization
To: PDSOs and DSOs at SEVP-certified schools
Date: August 12, 2026
BCM Number: 2608-01
General Information
The Student and Exchange Visitor Program
(SEVP) reminds all designated school officials (DSOs) of their responsibilities regarding curricular practical training (CPT) authorization as well as increased program oversight concerning the proper use of CPT. SEVP has observed a rise in CPT authorizations that do not meet regulatory requirements, specifically those not constituting an integral part of an established curriculum. As a result, the program is increasing its scrutiny of CPT approvals to ensure compliance with federal regulations. following information:
- CPT must be integral to the curriculum: training is an integral part of an established student’s major area of study. CPT cannot employment or for experiences that are not
Please carefully read and review the
DSOs can only authorize CPT when the curriculum and is directly related to the authorized solely for the purpose of required or otherwise formally recognized as part of the academic program. SEVP reserves the right to request documentation and other evidence from DSOs to identify whether CPT is indeed a core and essential part of the students’ studies, without which,
they would be unable to complete their degree. While SEVP recognizes that the school, not the U.S. government, defines what is and is not required to complete a degree,
SEVP is also committed to identifying and investigating schools that attempt to undermine or purposely bypass federal regulations or oversight. DSOs are reminded that F nonimmigrant students are, by their own attestation under penalty of perjury, here in the United States “solely for the purpose of pursuing a full program of study.” If SEVP suspects that school officials are abusing CPT to create work opportunities rather than academic studies, they may be subject to additional scrutiny and action from SEVP and Homeland Security Investigations (HSI), to include potential withdrawal of the school’s SEVP certification.
- DSO certification and legal responsibility: When you sign or re-sign the Form I-20, “Certificate of Eligibility for Nonimmigrant Student Status,” to authorize CPT, you are certifying under penalty of perjury that all information is true and correct to the best of your knowledge. This includes confirming that CPT is required or otherwise integral to the students’ curriculum. Potential liability: Improper CPT authorization, such as for non-integral purposes, may subject both the institution and individual DSO to administrative or legal consequences. This includes withdrawal of SEVP certification and potential penalties for providing false information or misrepresenting the nature of the training.
Actions requested: After reviewing the above information, DSOs should:
- Carefully review all CPT requests
requirements across all fields of study.
- Ensure that CPT is only authorized
your institution’s current academic
when it is truly integral to the program. Only authorize CPT if its absence would make the attainment of a degree an impossibility and if the work associated with that degree.
CPT is required for all students pursuing
- Maintain thorough records supporting the curricular necessity of each CPT
authorization.
- Consult with your SEVP field representative if you have questions about a
specific case. Employers, DSOs, students and members of the public can report suspected employment fraud, practical training fraud, or other instances of foreign students or certified schools abusing federal SEVPFraud@hsi.dhs.gov.
regulations directly to SEVP via email at
For questions about this message, please contact the SEVP Response Center (SRC) via phone at 703-603-3400 or 1-800-892-4829 or via email at SEVP@ice.dhs.gov. The SRC is open Monday through Friday, 8 a.m. to 6 p.m. ET, except for federal holidays. Thank you for your attention to this important matter and for your continued commitment to regulatory compliance. Disclaimer The Broadcast Message is not a substitute for applicable legal requirements, nor is it itself a rule or a final action by SEVP. It is not intended to, does not, and may not be relied upon to create any right or benefit, substantive or procedural, enforceable at law by any party in any administrative, civil, or criminal matter.
Appendix B: Broadcast Message: 2608-02
Broadcast Message: Guidance for Designated School Officials regarding Curricular Practical Training To: PDSOs and DSOs at SEVP-certified Schools
Date: August 24, 2026
BCM Number: 2608-02
General Information On August 12, 2026, the Student and Exchange Visitor Program (SEVP) issued Broadcast Message 2608-01. This broadcast informed
all Designated School Officials (DSOs) that SEVP has observed a rise in Curricular Practical Training (CPT) authorizations that appear to violate regulatory requirements which permit CPT only where the training is an integral part of an established curriculum. Accurate and timely reporting by schools and students allows SEVP to manage the Student and Exchange Visitor Information System (SEVIS), a critical tool in SEVP’s mission to protect national security and ensure the integrity of the nation’s educational and comply with SEVP regulations may result in foreign students.
exchange programs. Failure to an institution losing certification to enroll
The guidance below provides additional information on how CPT operates as an integral and required part of an educational experience.
- How is CPT defined in regulation? A foreign student may be authorized by a DSO to participate in a CPT program that is an integral part of an established curriculum. Curricular practical training is defined as alternative work/study, internship, cooperative education or any other type of required internship or practicum that is offered by sponsoring employers through cooperative agreements with the school.
- How is CPT different from Optional Practical Training? Optional Practical Training (OPT) is training established curriculum. OPT is not intended
that is not an integral part of a student’s to fulfill requirements of a student’s program of study and successful program completion does not require participation in OPT; it is optional. In contrast, CPT fulfills an integral element of an established curriculum and successful completion is contingent on participation in CPT. As defined by Merriam-Webster, “integral” means “essential to completeness” as in, “an integral part of the curriculum.”
- Can CPT be offered as a part of an elective course? In any instance where an elective course is integral and required aspects of CPT would
optional, making the CPT optional, the not be met. CPT is an integral part of an established curriculum and the practical training is required for all students participating in that curriculum, regardless of citizenship.
- Because CPT is allowed only where the training is an integral part of an
established curriculum, does that mean that all students enrolled in the established curriculum must participate in and complete practical training? Yes. Unlike OPT, participation in CPT is not optional for any student participating in an established curriculum that the school has determined requires CPT as an integral part of the educational experience. This means that all students — foreign and American — are required to participate in practical training if they are enrolled in an established curriculum where practical training is integral. While auditing and investigating schools to ensure compliance, SEVP has noted that some institutions have described CPT as if it is optional practical training and not integral, despite clear regulatory requirements. SEVP has also discovered that some institutions have not required all students enrolled in the same established curriculum to participate in practical training, despite clear regulatory requirements that CPT is permitted only where the practical training is an integral broadcast messages have clearly made this reminded DSOs of the integral and required
of an established curriculum. Prior distinction between CPT and OPT and elements of CPT.
- Are foreign students required to proactively request CPT authorization from
their DSO? Yes. Foreign students must make an official DSO so that the school can confirm that the curriculum where practical training is is directly related to the student’s major area
request for authorization for CPT to their student is participating in an established make a determination that the training of study, and update the student’s SEVIS record to ensure that DHS can conduct proper oversight as required under federal law. A DSO’s failure to maintain these verification and record-keeping requirements may face significant SEVP sanctions. 8 C.F.R. §§ 214.2(f)(10)(i); 214.3(l)(2); 214.4(a)(2).
- Must all CPT be conducted by sponsoring employers that have established
cooperative agreements with the school? Yes. Schools should only enter into cooperative agreements with legitimate, bona fide employers who are able to provide a quality
practical training experience to students. CPT students should have access to practical training managed by an employer who has entered into a cooperative agreement with a school where it is agreed the employer will sponsor the school’s students work/study, internship, cooperative or practicum that is specific to the student’s
for specific training such as an alternative or any other type of required internship major area of study. Students are not expected to obtain EADs for this training which is an integral and required part of the curriculum.
- As a DSO, what are my options if I believe I am being pressured by school
leadership to make questionable, improper, or otherwise noncompliant decisions and attestations on behalf of foreign students? DSOs serve a critical role in upholding the integrity of the nation’s foreign student program and serve as important partners with the federal government. If you believe you are being asked, directed, coerced, or you feel do not comply with regulations; we
pressured to make attestations want to hear from you. The new SEVP tipline serves as a confidential avenue for you to relay these concerns for further review by SEVP and Homeland Security Investigations (HSI). Please contact the SEVP Response Center (SRC) via phone at
703-603-3400 or 1-800-892-4829 or via email at SEVP@ice.dhs.gov. The SRC is open Monday through Friday, 8 a.m. to 6 p.m. ET, except for federal holidays.
Disclaimer
The Broadcast Message is not a substitute itself a rule or a final action by SEVP. It is
applicable legal requirements, nor is it intended to, does not, and may not be relied upon to create any right or benefit, substantive or procedural, enforceable at law by any party in any administrative, civil, or criminal matter.
Appendix C: CPT Regulations: 8 CFR 214.2(f)(10)(i)
Curricularpracticaltraining. An F-1 student in a curricular practical training program that
be authorized by the DSO to participate is an integral part of an established curriculum. Curricular practical training is defined to be alternative work/study, internship, cooperative education or any other type of required internship or practicum that is offered by sponsoring employers through cooperative agreements with the school. Students who have received one year or more of full time curricular practical training are ineligible for post-completion academic training. Exceptions to the one academic year requirement are provided for require immediate participation in curricular for curricular practical training must be
students enrolled in graduate studies that practical training. A request for authorization to the DSO. A student may begin curricular practical training only after receiving their Form I-20 or successor form with the DSO endorsement. To grant authorization for a student to engage in curricular practical training, a DSO will update the student's record in SEVIS as being authorized for curricular practical training that is directly The DSO will indicate whether the training is location, and the employment start and end
related to the student's major area of study. full-time or part-time, the employer and date. The DSO must sign, date, and return the Form I-20 or successor form to the student prior to the student's commencement of employment indicating that curricular practical training has been approved.