STEM OPT employer requirements: E-Verify, Form I-983, reporting and site visits

To keep an F-1 student through the 24-month STEM OPT extension, the employer must be enrolled in E-Verify and in good standing, have an IRS employer identification number, and sign the student's Form I-983 training plan. It must then deliver that plan: at least 20 hours a week of paid, supervised training directly related to the STEM degree, on terms that match similarly situated U.S. workers. It must also sign the student's evaluations, report material changes, report a termination or departure to the school within five business days, and accept DHS site visits. These are the requirements in force as of November 2026.

This page covers the employer's side of the extension. For hiring during the first 12 months, see hiring F-1 OPT students; for the move from OPT to H-1B, see the cap-gap guide.

What must be in place before the student applies?

• The student's eligibility. A bachelor's, master's or doctoral degree on DHS's STEM Designated Degree Program List, from a school that is accredited and SEVP-certified when the student applies, and a valid period of post-completion OPT. A student may receive at most two STEM extensions in a lifetime, the second only for a degree at a higher level.
• E-Verify. E-Verify's own FAQ says you must enroll, sign the memorandum of understanding and participate. The student's Form I-765 needs your company ID number, or a client company ID if an employer agent creates your cases, and E-Verify says you may give the student that number. See E-Verify enrollment steps if you are not enrolled yet.
• An EIN used for tax purposes.
• A signed Form I-983. The DSO cannot recommend the extension until the student submits the completed, signed plan.

Timing belongs to the student: Form I-765 may be filed up to 90 days before the current OPT card expires and must be filed within 60 days of the DSO's recommendation. An employer that wants to keep a student should sign the plan well before those dates.

What is the employer signing on Form I-983?

ICE's page on employers and the Form I-983 (updated May 7, 2026) says the employer completes Sections 3 to 6:

"Similarly situated U.S. workers" means people doing similar duties under similar supervision, with similar education, experience, responsibility and skills. If you employ two or fewer such workers, you still attest that the terms match those of comparable workers in the area of employment, under 8 CFR 214.2(f)(10)(ii)(C)(8). You may use an existing training program for supervision and evaluation, but USCIS says each plan must still be customized to the individual student.

Compensation must be real. USCIS says the employer may not be the student's employer in name only, and the student may not work on a volunteer basis; unpaid roles that are allowed during regular OPT are not allowed here.

When does the employer report to the school?

These come from 8 CFR 214.2(f)(10)(ii)(C)(6) and (9) and ICE's employer reporting page. If the student moves to a new employer during the extension, the student must submit a new Form I-983 within 10 days of starting, and the new employer must meet every requirement above.

Can a staffing agency or consulting firm employ a STEM OPT student?

Yes, but on narrow terms. USCIS's STEM OPT page says staffing and temporary agencies and consulting firms may employ STEM OPT students only if they are the entity that provides the practical training and they keep a bona fide employer-employee relationship with the student. Training can happen away from the employer's main office, but:

• the people who train and supervise must be the employer's own employees or contractors it retains directly, not employees or contractors of its clients;
• the employer may not assign or delegate its training responsibilities to a client or the client's staff;
• another student on OPT may never be the trainer;
• USCIS warns that multiple-employer arrangements, sole proprietorships, temp-agency employment and labor-for-hire consulting arrangements may not be able to show a bona fide relationship.

On E-Verify, the agency must be enrolled; E-Verify's FAQ says the third parties that contract for the student's services need not be. Report any change of work site through a modified Form I-983, because DHS uses the address for site visits. For the client side of agency placements, see E-Verify for staffing agencies and Form I-9 for staffing agencies.

What happens during a DHS site visit?

ICE's site visit page says DHS gives at least 48 hours' notice unless a complaint or other evidence of noncompliance triggers the visit. ICE staff check that the training matches the Form I-983, may confirm you have the resources and supervisors to run it, and may ask for the evidence you used to set the student's pay against similarly situated U.S. workers. DHS may ask by email or phone first, may refer matters to the Labor Department, and sends any request for corrected information in writing. Keep the wage comparison you relied on in the student's file.

How do the 180-day extension and Form I-9 work?

If the student files the STEM extension on time and the OPT card expires while it is pending, 8 CFR 274a.12(b)(6)(iv) authorizes work for up to 180 days or until USCIS decides, whichever comes first. This provision was not part of the 2025 change that ended most automatic EAD extensions: that rule, finalized on October 14, 2026, amended only 8 CFR 274a.13, and the 180-day text is still in the eCFR in November 2026.

On Form I-9, M-274 Section 7.4.2 treats the expired EAD plus a Form I-20 endorsed for the extension as the document. For a current employee, enter "EAD EXT" and the date 180 days after the card's "Card Expires" date in Additional Information, then reverify on Supplement B by that date; see I-9 reverification and Form I-9 for F-1 OPT students. You do not create a new E-Verify case for the extension.

Unemployment is capped at 150 days across post-completion OPT and the extension combined, under 8 CFR 214.2(f)(10)(ii)(E).

What changed in 2026?

• An extension of stay step. Under the fixed-admission rule effective September 15, 2026 (91 FR 44976), students who need more time in the US for STEM OPT generally also apply for an extension of stay. A student who was in the US on duration of status on September 15, 2026 and files the STEM OPT application before the current OPT card expires and on or before March 18, 2027 does not need the separate filing (8 CFR 214.1(m)(1)(i)). The employer's obligations did not change.
• A proposed OPT fee. ICE's October 8, 2026 proposal would have schools pay $30,000 for each OPT recommendation after the first, which includes STEM OPT. It is not in effect.

What should recruiters say about STEM OPT?

Ask every candidate the two questions on work authorization in interviews and nothing more about status. Decide as a company whether you will support STEM extensions, which depends on being in E-Verify and having someone who can run a real training plan, and say so consistently. Do not ask candidates to show their EAD, I-20 or degree-list status before an offer; the school and your counsel handle eligibility.

A STEM OPT employer checklist

• Confirm E-Verify enrollment and good standing for the hiring site before the student's card expires.
• Name a supervisor who will train and evaluate the student, and an official who can sign.
• Document how you set pay against similarly situated U.S. workers.
• Calendar the 12-month and final evaluations, and the five-business-day reporting window.
• Route every change in hours, pay, duties, site or EIN through HR so a modified Form I-983 goes out.
• Enter "EAD EXT" during the 180-day period and reverify on time.