Form I-9 for CPT students: the endorsed Form I-20, Section 1 and List A entries, the 2026 admission rule and SEVP's cooperative-agreement guidance

An F-1 student on curricular practical training (CPT) has no Employment Authorization Document; their permission to work is the endorsement their designated school official (DSO) puts on Form I-20. On Form I-9, the student checks "An alien authorized to work" in Section 1 and enters the CPT employment end date from the I-20, and in Section 2 the employer usually records the List A combination of unexpired foreign passport, Form I-94 showing F-1 status and the I-20 endorsed for CPT. As of November 2026, three things matter most: the I-20 must name your company, the work location and the dates; students admitted under the DHS rule effective September 15, 2026 have a fixed I-94 date, and their CPT can continue for up to 240 days while a timely extension of stay is pending; and SEVP told schools in August 2026 that CPT must be a required part of the curriculum, offered by employers through cooperative agreements.

The OPT and STEM OPT version of these rules is in Form I-9 for F-1 OPT students, and the hiring decisions around student work are in hiring F-1 OPT students. Document choice is covered in I-9 List A, B and C documents, and Supplement B in I-9 reverification.

How is CPT different from OPT on Form I-9?

How do you complete Form I-9 for a CPT hire?

1. Check the I-20 before day one. The regulation says a student "may begin curricular practical training only after receiving their Form I-20 or successor form with the DSO endorsement," and the DSO records "whether the training is full-time or part-time, the employer and location, and the employment start and end date." M-274 7.4.2 says an acceptable I-20 for CPT "must have all Employment Authorization fields completed," including the employer's name and location. Set the first day on or after the CPT start date for your company.
2. Section 1. The student checks "An alien authorized to work," enters the CPT employment end date as the date authorization expires, and gives a USCIS Number or A-Number, the I-94 admission number, or a foreign passport number and country.
3. Section 2, List A. Record the three documents in the three sets of List A fields: the foreign passport, the I-94 showing F-1 status, and the I-20 with the DSO's endorsement. M-274 7.4.2 says to "use the CPT Employment End Date on Form I-20 as the expiration date in Section 2."
4. Or List B and List C. If the student shows, for example, a state driver's license, record it under List B and the I-94 with the endorsed I-20 under List C #7, and enter the I-20 in the Additional Information field, as the handbook instructs.
5. Let the student choose. The Form I-9 instructions say the employer "cannot specify which documentation an employee may present." Asking for a SEVIS printout or a school letter on top of acceptable documents is not part of Form I-9.
6. E-Verify, if you use it. Create the case by the third business day after the start, as for any new hire.
7. Diary the CPT end date for reverification.

What does the 2026 F-1 admission rule change for CPT?

The DHS rule at 91 FR 44976, published July 17, 2026 and effective September 15, 2026, replaced "duration of status" for F-1 students with a fixed admission period. The parts that reach an employer's Form I-9:

• New admissions. Students admitted on or after September 15, 2026 receive an Admit Until Date on Form I-94, set from the program on the I-20, up to four years, with up to 30 days before the program start and 30 days after the program end date (8 CFR 214.2(f)(5)(i)).
• Students already in duration of status. Under the new 8 CFR 214.1(m)(1), students properly maintaining status on September 15, 2026 may remain until the later of their EAD expiration or their I-20 program end date, but no later than November 14, 2030, and "any authorized employment or training continues" as endorsed on the I-20. Their I-94 can still read "D/S," and their CPT works on the form as before.
• Pending extensions of stay. Under the new 214.2(f)(5)(viii), a student who timely files to extend their stay keeps current CPT for up to 240 days from the I-94 end date while USCIS decides. For Form I-9, the authorized employment period, "which ends 30 days before their Form I-94 or successor form admit until date," plus the USCIS receipt for the extension, is treated as unexpired for up to 240 days or until USCIS decides, "or for CPT, until the CPT end date authorized by the designated school official on the Form I-20," whichever is earlier.
• Late filings. DHS's preamble says that if the extension is filed during the 30-day departure period, "the F-1 student does not receive an automatic extension of CPT and must wait for approval."
• No change to CPT itself. DHS says the rule "does not make substantive changes to the eligibility or the process for requesting CPT authorization."

As of November 2026 the M-274's F-1 section still shows a last update of April 2, 2025 and does not yet describe the new I-94 dates. For a student admitted under the new rule, compare the CPT end date with the I-94 Admit Until Date; if the CPT runs into the final 30 days, ask the student to check with their DSO before you rely on it, and watch Form I-9 related news for new guidance.

What does SEVP's August 2026 guidance mean for employers?

The regulation defines CPT 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." ICE's practical training page tells students that "CPT requires a signed cooperative agreement or a letter from your employer." On August 24, 2026, SEVP's Broadcast Message 2608-02 to school officials followed an August 12 message reporting "a rise in Curricular Practical Training (CPT) authorizations that appear to violate regulatory requirements." Its points for employers:

• CPT must be required for every student in the curriculum, "foreign and American"; training attached to an optional elective course does not meet the integral and required test.
• Schools "should only enter into cooperative agreements with legitimate, bona fide employers who are able to provide a quality practical training experience to students."
• Students "are not expected to obtain EADs for this training."
• Schools that fail to comply risk losing certification to enroll foreign students.

In practice, put the internship's real duties, hours, location and dates in the letter or agreement the school asks for, make sure they match the I-20, and do not ask a student to obtain CPT for a role unrelated to their major. The DSO, not the employer, decides whether the training qualifies.

One related proposal: on October 8, 2026 DHS proposed fees of $70,000 for initial OPT and $30,000 for subsequent OPT (91 FR 64566; comments closed November 9, 2026). DHS says the proposal "is specific to OPT and does not address CPT." It is not a final rule, but it matters to employers that plan to convert interns into OPT hires.

When do you reverify a CPT student?

• At the CPT end date. M-274 Section 6.1 says to reverify "no later than the date employment authorization expires." If the DSO extends the CPT, the student can show a newly endorsed I-20 with the passport and I-94 (List A) or with the I-94 under List C, on Supplement B; any other List A or List C document also works.
• Moving to OPT with you. Post-completion OPT needs an EAD, and the M-274 says the student "may not begin employment until the date indicated on the EAD." A gap between the CPT end date and the EAD start is time the student cannot work. Record the EAD on Supplement B.
• Coming back for a second term. A student who returns after a break with a new CPT endorsement for your company is a rehire; see Form I-9 for rehires.
• CPT for another employer. An I-20 naming a different employer or location does not cover work for you.

What should recruiters and hiring managers avoid?

• Collecting immigration papers before an offer. The two standard work authorization questions are enough at screening; see work authorization questions in interviews.
• Starting early or running late. No work before the I-20 start date or after the end date without a new endorsement.
• Changing the terms quietly. If hours move from part-time to full-time, or the work moves to another site, ask the student to have the DSO update the I-20 before the change.
• Rejecting short dates. A CPT end date a few months out is normal; employers "should not reject acceptable documentation due to a future expiration date."

A CPT Form I-9 checklist

• I-20 endorsed for CPT with your company's name, the work location, full-time or part-time, and start and end dates.
• First day on or after the CPT start date.
• Section 1 date: the CPT end date.
• Passport, I-94 and I-20 in List A, or List B plus the I-94 and I-20 under List C with the I-20 in Additional Information.
• For students admitted on or after September 15, 2026: CPT end date compared with the I-94 Admit Until Date.
• Cooperative agreement or employer letter on file with the school, matching the I-20.
• Reverification at the CPT end date, and an EAD before any OPT work.