Form I-9 for F-1 OPT students: EAD entries, the STEM 180-day extension, cap-gap and the 2026 admission rule

An F-1 student on optional practical training (OPT) usually completes Form I-9 with an Employment Authorization Document (Form I-766), which is a List A document: in Section 1 they check "An alien authorized to work until" and enter the EAD's Card Expires date, and in Section 2 the employer records the EAD and reverifies on Supplement B when it expires. Two automatic extensions can keep an expired-looking OPT EAD valid: up to 180 days while a timely STEM OPT extension application is pending, and the cap-gap extension to April 1 when the employer has timely filed an H-1B cap petition. Employers of STEM OPT students must also be enrolled in E-Verify. All of this is as of November 2026.

This page covers the Form I-9 side of hiring OPT and STEM OPT students. The hiring decisions around it are in hiring F-1 OPT students; for the H-1B side of cap-gap, see Form I-9 for H-1B workers; for what a recruiter may ask a student before an offer, see work authorization questions in interviews.

Which documents does an F-1 student present for each kind of work?

The employee always chooses which acceptable documents to present. What changes by work type is where the Section 1 expiration date comes from and what usually appears in Section 2. This table follows the M-274's Table 6:

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

1. Check the start date against the EAD. The M-274 says an OPT student may not begin employment until the date indicated on the EAD, so the first day of employment cannot be earlier than the card's validity start.
2. Section 1. The student checks box 4, enters the EAD's Card Expires date as the date their authorization expires, and enters their USCIS Number or A-Number, Form I-94 admission number, or passport number and country.
3. Section 2. Under List A, enter "EAD", the issuing authority, the card number and the Card Expires date. Do not ask for Form I-20 or a List B document as well; an unexpired EAD completes Section 2 on its own.
4. E-Verify, if you use it. Create the case by the third business day after the start date, as for any new hire, and keep a copy of the EAD, which E-Verify employers must retain.
5. Diary the reverification date: the Card Expires date, or an earlier date entered in Section 1.

How does the STEM OPT 180-day extension work on Form I-9?

Under 8 CFR 274a.12(b)(6)(iv), a student whose post-completion OPT EAD expires while a timely filed STEM OPT extension application is pending may keep working from the expiration date until USCIS decides the application, for no more than 180 days. For that period the old EAD counts as unexpired when combined with a Form I-20 on which the designated school official recommends the extension; if the student has changed employers, that I-20 must show the new employer. This extension is separate from the general EAD renewal extension that DHS ended in October 2025 and confirmed in a final rule on October 14, 2026, and USCIS's Employment Authorization Extensions page still lists it as of November 2026.

• New hire: under List A enter "EAD", the EAD number, and the date 180 days from the Card Expires date as the expiration date, then "EAD EXT" in Additional Information.
• Current employee: review the endorsed Form I-20 and enter "EAD EXT" and the date 180 days from the Card Expires date in Additional Information, initialed and dated. If their original form is an edition that is no longer valid, make the note on Section 2 of a current edition and keep it with the original.
• Reverify on Supplement B by the date you entered, or as soon as the new STEM EAD arrives, which the employee may present at any time.

An example with illustrative dates: an employee's post-completion OPT EAD shows Card Expires June 30, 2027, and they filed for the STEM extension in time. On July 1 they show the expired EAD and an I-20 endorsed for STEM OPT with your company's details. You enter "EAD EXT 12/27/2027" (June 30, 2027 plus 180 days) and diary December 27, 2027. If the STEM EAD arrives in September, you reverify then; if USCIS denies the application, the extension ends with the decision.

What else does an employer of a STEM OPT student have to do?

Form I-9 is only one part. The STEM OPT rules in 8 CFR 214.2(f)(10)(ii)(C) put duties directly on the employer:

• E-Verify. The employer must be enrolled in E-Verify and remain a participant in good standing, and any new employer or new hiring site must be enrolled before the student starts there. The student needs your E-Verify company identification number to apply. See E-Verify enrollment steps.
• Form I-983. An appropriate person in your organization signs the training plan, and you sign a modified plan for material changes, such as a cut in pay not tied to fewer hours.
• Reporting. You must report the student's termination or departure to the school's designated school official within five business days.
• Terms and hours. Duties, hours and pay must be commensurate with similarly situated U.S. workers, and the training must be at least 20 hours a week.
• Site visits. DHS may visit, normally with 48 hours' notice.

ICE's Student and Exchange Visitor Program keeps employer materials on its STEM OPT Hub; the employer duties are set out in full in STEM OPT employer requirements.

How does cap-gap show up on Form I-9?

If you timely file an H-1B cap petition asking for a change of status for a student on post-completion OPT, the student's status and OPT work authorization are automatically extended until April 1 of the fiscal year requested, or the start date of the approved petition if earlier. The expired EAD plus your Form I-797C receipt notice is an unexpired List A document. For a new hire, Section 1 shows March 31 of that fiscal year, and Section 2 shows "EAD", the I-797C receipt number, the same March 31 date and "CAP-GAP". For a current employee, enter "CAP-GAP" and the March 31 date in Additional Information. The extension ends if the petition is rejected, denied, revoked or withdrawn. When the petition is approved, reverify by March 31 using the new Form I-94 that comes with the approval notice, or any other List A or C document the employee chooses. The employer's side of cap-gap is in H-1B cap-gap for employers.

What changed for F-1 students in 2026?

DHS's final rule at 91 FR 44976, published July 17, 2026 and effective September 15, 2026, ended "duration of status" for F students. The points that touch hiring:

• Fixed admission dates. Students admitted on or after September 15, 2026 get an Admit Until Date on Form I-94 instead of "D/S", tied to the program length on Form I-20, up to four years plus 30 days for arrival and 30 for departure. The departure period after study or OPT is now 30 days, down from 60.
• Students already here. Students admitted for duration of status and maintaining status on September 15, 2026 may remain without filing an extension until the later of their EAD expiration or their I-20 program end date, plus a departure period, and in no case after November 14, 2030. Those who file for post-completion OPT or STEM OPT on or before March 18, 2027 do not also need to file an extension of stay.
• On-campus and CPT work. A student who timely files an extension of stay keeps on-campus, CPT and certain severe-economic-hardship work for up to 240 days while it is pending. For Form I-9, 8 CFR 214.2(f)(5)(viii) treats the authorized employment period, which it says ends 30 days before the I-94 Admit Until Date, together with the USCIS receipt for the extension, as unexpired for up to 240 days or until USCIS decides; for CPT, no later than the CPT end date on the I-20.
• OPT and cap-gap. DHS said the rule makes no substantive changes to OPT or CPT other than admission and extensions, and no change to the cap-gap rule.

As of November 2026, the M-274's F-1 section had not been revised for the rule; it still shows a last update of April 2, 2025. Check Form I-9 related news for new guidance before relying on an I-94 date for an on-campus or CPT hire.

When do you reverify an OPT or STEM OPT employee?

• When the EAD expires, on Supplement B, unless an extension above applies.
• When a STEM "EAD EXT" date arrives, or earlier when USCIS decides the STEM application.
• By March 31 for a cap-gap employee whose H-1B status has not yet started.

At each point the employee may present any unexpired List A or List C document; they do not have to show the same kind of document again. Do not create a new E-Verify case for a reverification. Moving from OPT to STEM OPT with you is a reverification; joining a new employer during the STEM period is a new hire with a new Form I-9, a new E-Verify case and a new Form I-983. The Supplement B steps are in I-9 reverification.

What should recruiters avoid with OPT candidates?

• Asking for the EAD, the I-20 or a SEVIS printout before an offer is accepted. Before then, the two standard work authorization questions are enough.
• Rejecting a valid EAD because it expires soon. The Form I-9 instructions say employers should not reject acceptable documentation because of a future expiration date.
• Promising a STEM extension or an H-1B filing in an offer without the employer's immigration counsel signing off; both create employer obligations.

An OPT hiring checklist

• Start date on or after the EAD's validity start date.
• Section 1 expiration date matches the EAD, the 180-day date, or March 31 for cap-gap.
• EAD recorded under List A, with "EAD EXT" or "CAP-GAP" notes initialed and dated where they apply.
• For STEM OPT: E-Verify enrolled at the hiring site, Form I-983 signed, five-business-day reporting set up.
• Reverification dates in your calendar, not only in E-Verify's alerts.
• No new E-Verify case at reverification.