For decades, Curricular Practical Training (CPT) has been one of the most flexible tools available to F-1 students and the schools that enroll them — a way to gain real-world, degree-related work experience without the wait times or paperwork burden of Optional Practical Training. That flexibility may no longer exist as the Student and Exchange Visitor Program (SEVP) recently issued messages that, taken together, threaten to eviscerate the CPT program as most schools and students have practiced it.
Two Memos, One Message
On August 12, 2026), SEVP’s memo, “Reminder of Liability for DSOs Regarding CPT Authorization,” the agency noted a rise in what it alleged were CPT authorizations that did not meet regulatory requirements — specifically, training that was not truly an integral part of an established curriculum. SEVP framed this as a reminder of existing law rather than a new rule, but the memo’s purpose was unmistakable: schools that it believed were authorizing CPT loosely were under heightened scrutiny, with consequences reaching all the way to loss of SEVP certification.
On August 24, 2026, SEVP removed any doubt about its intent to regulate CPT more aggressively. In this memo, SEVP detailed how it will determine if CPT is “integral” to an established curriculum. This memo defines the term using its plain dictionary meaning (“essential to completeness”) and draws conclusions that upend how many schools currently administer CPT programs. Specifically, the memo indicates:
- Electives are disqualified. If the underlying course is optional, any CPT tied to it cannot be “integral and required” by definition.
- All students must participate — not just international students. If a curriculum genuinely requires practical training, every student in it, domestic and foreign alike, must complete that training. A program that lets international students opt into CPT while their U.S. citizen classmates opt out no longer qualifies.
- Designated School Officials (DSOs) are reminded of their verification and SEVIS recordkeeping obligations, with explicit sanctions warned for DSOs who don’t document that a given placement is both curriculum-required and major-related.
- Cooperative agreements with employers may face new scrutiny, as DSOs are reminded to only enter into cooperative agreements with legitimate, bona fide employers capable of providing a quality practical training experience to students, a clear signal that SEVP will look past the paperwork to evaluate whether the employer’s training program is genuine.
- SEVP has a confidential tipline for DSOs to report internal pressure to approve questionable CPT requests, effectively deputizing school staff as an enforcement channel against their own institutions.
An Extinction-Level Event for CPT as We Know it?
Neither memo changes the regulations but the practical effect of reading “integral” so narrowly is to eliminate the CPT model that a large share of graduate programs, especially STEM and business master’s programs built around “Day 1 CPT”, have relied on for years. Under the new interpretation:
- A curriculum that lets any student substitute a different elective, project, or capstone for the internship no longer qualifies.
- A curriculum where only international students routinely pursue the “practical training” option, while domestic students overwhelmingly choose something else, is now presumptively impermissible, even if the option is open to everyone.
- Schools can no longer view CPT as an option in an otherwise structured degree. It has to be incorporated into the degree’s actual completion requirements, and apply to all students seeking the degree.
That is a fundamentally different, and far narrower, program than most DSOs have been administering. Academic institutions nationwide are best advised to review existing CPT authorizations, and consider pausing new authorizations, while they reassess their compliance with the new guidance.
What Employers Should Do Now
- Review cooperative agreements with schools to confirm the training relationship is genuine. Employers should be prepared to show that the arrangement reflects real training as opposed to staffing a regular position at the company.
- Confirm the CPT student’s curriculum requires the placement. Employers would be wise to request the DSO provide written confirmation that the training is a required, integral part of the student’s academic program.
- Reassess any Day-1 CPT hires. Roles filled through curricula built around immediate, degree-long practical training are the most vulnerable to the narrower reading of “integral.” Employers should have a contingency plan if a school suspends Day-1 CPT authorizations for incoming or current trainees.
- Loop in counsel before an HSI inquiry. With a new confidential tipline funneling concerns about improper CPT authorizations straight to SEVP and Homeland Security Investigations (HSI), employers who regularly rely on CPT talent should consider consulting with immigration counsel to assess potential exposure.
Our Perspective
While SEVP indicates that nothing has changed in the regulations, when an agency redefines a critical component of eligibility and backs it with severe consequences for schools and their students, while at the same time adding a whistleblower tipline, schools, students and CPT employers should treat these two memos as an unequivocal message that SEVP intends to put an end to the CPT program as it has operated for many years.
If you are a school looking to reassess your CPT program, an employer relying on CPT talent, or an F-1 student trying to understand what this means for your specific CPT placement, our immigration team is available to advise you.
