CPT Rules: What F-1 Students in NYC Need to Know

On August 12, 2026, the Student and Exchange Visitor Program (SEVP), overseen by the U.S. Immigration and Customs Enforcement (ICE), sent a memo to U.S. university officials restricting the issuance of international students’ Curricular Practical Training (CPT). 

Almost two weeks later, on Aug. 24, ICE issued a follow-up memo that went further. “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,” the agency said.

Schools that fail to comply, the memo warned, risk losing their certification to enroll foreign students. The underlying regulation has not changed.

ICE said in the memo that, through SEVP, it “has observed a rise in CPT authorizations that do not meet regulatory requirements.”

This policy update comes as part of a broader tightening of student visa and legal immigration pathways under the Trump administration.

Documented spoke with immigration attorney Camiel Becker to get a clearer understanding of what’s changing and what students should do next. 

What is Curricular Practical Training (CPT)?

CPT is a program that allows international students with an F-1 visa to gain practical work experience off-campus paid or unpaid.

The program has to be an integral part of the established curriculum of the student’s major — either required of all students in the degree program, or required by a credit-bearing course that counts toward the degree. 

CPT must be authorized by the school with a new Form I-20 issued, before the student begins work.

Why are the recent changes confusing?

Becker said the first memo doesn’t necessarily change the underlying CPT rules. The Aug. 24 memo went further, requiring that practical training “is required for all students participating in that curriculum, regardless of citizenship.”

That condition, Becker said, appears nowhere in the regulation. “This is arguably a stricter interpretation not explicitly stated in the regulations,” he said. The existing regulation, he noted, “says only that CPT must be ‘an integral part of an established curriculum.’ It does not say that CPT must be required ‘for all students in the program,’ and it does not prohibit the use of CPT for an elective course.”

“Nothing in the [existing] regulation prohibits an interpretation that CPT could qualify when offered through any credit-bearing course, even if that course is elective,” he said.

However, the memo’s practical effect falls hardest on students whose internships aren’t mandatory for their major — the elective-course route, which many use for summer internships and on PhD students who need additional practicums for their research.

Specifically, the Aug. 24 memo states that if a course tied to CPT is optional within the student’s degree program, the training is not considered an integral part of the established curriculum, which effectively closes the course-credit route.

The memos, sent to SEVP-certified universities, also warns that school officials who improperly authorize CPT could face personal liability, and that institutions failing to comply could lose their ability to enroll international students. 

How did the universities respond to this new memo?

Several outlets recently reported that some universities, including the University of California, Berkeley, Davis, San Diego, University of Washington, and Barnard College in New York City have temporarily suspended either all applications for CPT or partially for course credit CPT while awaiting guidance from legal counsel.

In New York, Columbia University recently updated its website: “Following the messages posted in August, we have updated our CPT approval process to be consistent with the advisories.”  

In its FAQ section about CPT, Columbia says that it will “only authorize CPT that is integral to the academic curriculum, required of all students in the program, and documented with a cooperative agreement.” All other CPT authorizations — the school says —- “are currently paused for programs in which CPT is not a mandatory degree requirement of all students in the program.”

New York University (NYU) has also acknowledged the recent memos on its website. “This new guidance establishes a stricter federal interpretation of CPT rules, asserting that CPT may only be authorized if it is an explicit, mandatory degree requirement for all students (both domestic and international) enrolled in that specific program,” the school says.

NYU also says that it is “actively reviewing degree requirements across all programs to determine CPT eligibility under the new guidance.”

What can students do at this point?

Becker suggests that students should keep a log of two things:

• Your relation with the school, including your attendance, transcripts, school projects, assignments, email exchanges with the international services office.
• The work relation with your degree, including any letters, job description, working hours, recommendation from employers.

He also advises students: “Knowing the rule, knowing the regulation, and making sure that you have proof of compliance and keeping it is probably best practice.”

On its website, NYU also suggests students be “prepared to adjust” their Fall 2026 course schedule “with alternative credit-bearing coursework” to maintain their required full-time enrollment in case their CPT request is not approved.

What happens if my CPT has already been approved?

If your CPT was approved for the fall 2026 semester, your authorization generally still stands. Several universities, including Columbia University and the University of Southern California, have said they will not rescind CPT authorizations issued before Aug. 24. You may continue working for the employer and through the dates listed on your I-20.

Policies vary by school. Check your I-20 to confirm your authorization is still valid, and contact your school’s international student office right away if anything about your status has changed.

It’s important to know: international students cannot work off campus, paid or unpaid, without proper authorization. Working without it is a violation of F-1 status, and it can jeopardize your ability to stay in the U.S., to obtain future work authorization such as Optional Practical Training (OPT), or to get a visa later on.