F-1 Pre-Completion OPT

There are several types of work authorization for F-1 students. F-1 students maintaining status may be eligible for on-campus employment or volunteering and unpaid internships. For off-campus, paid employment, F-1 students may apply for Curricular Practical Training (CPT) from ISEO or Pre-Completion OPT from USCIS.

To be eligible to apply for Pre-Completion OPT,  you must meet the following requirements:  

• You are maintaining F-1 status.  
• You would like to work in a paid off-campus job that is directly related to your major/field of study, but you are not  eligible for Curricular Practical Training (CPT).   
• Your Pre-Completion OPT start and end dates must fall  within your program of study dates.   
• You must  be enrolled in  a predominantly in-person full-time course of study (or  be properly authorized for Reduced Course Load(s)) during the entire period of requested Pre-Completion OPT.  
  • Note: The full-time enrollment requirement does not apply to the student’s annual vacation period or the breaks between quarters. Review information on international student  Full-Time Enrollment Requirements.  
• You have not previously been authorized for 12 months of full-time Curricular Practical Training (CPT) at the same degree level for which you are requesting Pre-Completion OPT.  
• You have not previously completed 12 months of full-time OPT at the same degree level.  
• Undergraduate students:  You must have declared a major.  Pre-majors and undeclared majors are not eligible for OPT.  
• One Academic Year Requirement:  You must have been enrolled on a full-time basis for at least one academic year (3 quarters) on the same SEVIS number.   
  • It is ultimately at the discretion of USCIS  to decide whether a student has met the One Academic Year Requirement for OPT eligibility. However, ISEO may be able to recommend a student for Pre-Completion OPT if they have accrued time toward the One Academic Year Requirement through the following potential ways:  
    • SEVIS Transfer: You may use time spent in another SEVIS approved university or college if you were enrolled full-time and did a timely SEVIS transfer using the same SEVIS record. If you request Pre-Completion OPT during your first year at UC San Diego, ISEO will need an official transcript and a copy of your I-20 from your previous institution. Time spent enrolled in language training does not count towards the One Academic Year Requirement.  
    • Change of Status: You may use time spent in another non-immigrant status (e.g., E-2, H-4, L-2) if you were enrolled full time at a SEVIS approved university or college for one academic year. You can use your Form I-94 and academic history to show full-time enrollment spent in a different non-immigrant status.  
    • Change of Academic Level: You may use time spent at a lower degree level towards the One Academic Year Requirement if you were approved for a change of level with the same SEVIS record.  
  • Reduced Course Load authorizations: Students enrolled in less than 12 units with a properly authorized Reduced Course Load (RCL) are still considered full-time and may count the RCL term towards eligibility for the One Academic Year Requirement. 

You must maintain the following Employment Requirements if USCIS authorizes you for Pre-Completion OPT:  

• Employment must be directly related to your major/field of study.  
• If authorized for part-time Pre-Completion OPT, you may only work 20 hours or less per week. See below for more information on part-time vs. full-time Pre-Completion OPT.  
• All U.S.-based employers and their employees are required to adhere to the U.S. Department of Labor’s Fair Labor Standards Act.  

You do not need to have a job offer to apply for Pre-Completion OPT.   

Periods of unemployment are allowed while on authorized Pre-Completion OPT. However,  be aware that any time authorized for Pre-Completion OPT is deducted from the time available for Post-Completion OPT, whether the student obtains employment or not. See the next drawer below,  Pre-Completion OPT deducts from Post-Completion OPT, for more information.  

Hours: Part-time vs. Full-time OPT  

Pre-Completion OPT may be authorized at part-time or full-time status. Each request for part-time or full-time Pre-Completion OPT requires a new and separate application to USCIS. Part-time and full-time OPT are separate authorizations  that require separate applications  to USCIS.   

• For example: If a student authorized for part-time Pre-Completion OPT desires to work full-time during the summer term, the student must obtain a new OPT I-20 from ISEO and then submit a new application to USCIS to request full-time Pre-Completion OPT.   

Eligible F-1 students may request a total of 12 months of full-time initial Optional Practical Training (OPT) per degree level. This total duration of OPT may be split between Pre-Completion OPT and Post-Completion OPT.  

IMPORTANT!  

• Students are responsible for tracking their Pre-Completion OPT usage and determining the amount of Post-Completion OPT time for which they are eligible.   
• Impact on 2-year STEM Extension: Students who utilize all 12 months of initial OPT during their program of study (Pre-Completion OPT):  
  • are not eligible for initial Post-Completion OPT after they graduate; and  
  • are not eligible for the 2-year STEM OPT Extension.  
• Each request for part-time or full-time Pre-Completion OPT requires a new application to USCIS. Part-time and full-time OPT are separate authorizations  that require separate applications  to USCIS.  

Planning in Advance for Pre-Completion OPT  

• It is your responsibility to plan accordingly for university and USCIS processing times, and to communicate this timeline to your prospective employer when discussing your employment start and end dates with them.  
• Do not begin working until you have received your Pre-Completion OPT Employment Authorization Document (EAD card) and the start date of your EAD has arrived. Working before the start date on your EAD card is a violation of F-1 status. Any delays to your Pre-Completion OPT application processing may delay your requested EAD start date.  
• ISEO does not expedite OPT I-20 requests under any circumstances. ISEO's normal processing time is approximately 10 business days after your College/Department has approved the request (if required). 

The Earliest You Can Apply  

You must submit your Pre-Completion OPT application (Form I-765) to USCIS: 

• no earlier than 90 days before you complete the One Academic Year Requirement.  
• no earlier than 90 days before your requested OPT start date.  
• no later than 30 days after the “Date Issued” on your OPT I-20. 

Students who submit their application outside of their eligibility window will receive an OPT denial from USCIS. 

Overview of Pre-Completion OPT application timelines  

Plan for long processing times when applying for Pre-Completion OPT. Use the chart below to understand how long OPT processing may take. 

Your Form I-20 may be shortened because of Pre-Completion OPT  

When you request your Pre-Completion OPT I-20, you must indicate your anticipated program completion date in the iServices request.  

• If you report that you will be graduating earlier than your Form I-20's program end date, your I-20 will be shortened to match the anticipated program completion date you report in your OPT I-20 request. This is to ensure your Pre-Completion OPT does not get authorized beyond your true Program End Date.  
• If you report that you will be graduating later than your Form I-20's program end date, you must apply for a Program Extension and may need to file an Extension of Stay application with USCIS before ISEO can process your Pre-Completion OPT I20. Your Pre-Completion OPT end date cannot go past the current program end date shown on your I-20.   

Review ISEO’s Understand your Program End Date information to learn more about the program end date on your Form I-20 vs. your true Program End Date.  

Students who later need to extend their program of study and Form I-20 must apply for a Program Extension and may need to file an Extension of Stay application with USCIS.  

Choosing your requested Pre-Completion OPT start and end dates  

To request your Pre-Completion OPT I-20 from ISEO, you must indicate your requested OPT start and end dates in the iServices request.  

• Requested OPT Start Date: Your requested Pre-Completion OPT start date is chosen by you. Your requested start date must be a date after you have completed the One Academic Year Requirement. 
  • If you hope to apply for Pre-Completion OPT as soon as you meet the One Academic Year Requirement, refer to the relevant Academic Calendar to understand Quarter end dates. 
    • Example: A student who begins their program of study with the Fall quarter, and remains enrolled full-time during the Fall, Winter, and Spring quarters, becomes eligible for Pre-Completion OPT the day after the Spring quarter ends. The day after the Spring quarter ends is the earliest OPT start date the student can request. 
  • Be sure to keep Pre-Completion OPT processing times in mind when choosing your requested start date. If USCIS cannot complete processing prior to your requested start date, they will assign you a later start date based on when they complete review of your application.  
• Requested OPT End Date: Your requested Pre-Completion OPT end date cannot be later than: 
  • • 364 days from your requested OPT start date; NOR  
    • your Form I-20's program end date.  
  • Compare dates and ensure your requested OPT end date does not go past the earliest of these.  

IMPORTANT!  

• You cannot change your requested OPT start and end dates after you submit your Form I-765  application to USCIS. Take care to select these dates with accuracy!  

IMPORTANT! USCIS must receive your completed online OPT application (Form I-765) no later than 30 days after the “Date Issued” on your Pre-Completion OPT I-20 is issued by ISEO. You should not request your OPT I-20 from ISEO until you are ready to submit your OPT application to USCIS.  

To submit a Pre-Completion OPT I-20 Request in iServices:   

• Find the Working in the U.S. category in the left menu.  
  • Select Initial OPT Requests.  
  • Choose the Pre-Completion OPT I-20 Request option according to your degree level.  
• Submit all of the required eForms. You will receive a confirmation email when your request has been successfully submitted.  
  • NOTE: This request will first be sent to your college (undergraduates) or department (graduates) for review if required, reflected as 'Routed to Third Party' status in iServices. Upon college/department approval, it will then be forwarded to ISEO for review, indicated as 'Pending Office Approval' status in iServices. 

ISEO Processing Times: ISEO has an average processing time of approximately 10 business days after your college/department has approved the request (if required). ISEO does not expedite OPT I-20 requests under any circumstances. You will be notified via email when your request is complete.  

ISEO has an average processing time of approximately 10 business days to review your Pre-Completion OPT I-20 Request, after your college/department has approved it (if required). ISEO does not expedite OPT I-20 requests under any circumstances. You will be notified via email when your request is complete.  

When you receive your OPT I-20:  

• Review your OPT I-20 for accuracy.  
  • Page 1: Check the issue date of the OPT I-20, and also your program end date.  
    • Note the “Date Issued” date near the ISEO Advisor’s signature. You must submit your complete online OPT application (Form I-765) to USCIS no later than 30 days from the “Date Issued” date.  
    • If your Form I-20 has been shortened, note your new program end date.  
      • If your program end date is now earlier than the Admit Until Date (AUD) on your most recent Form I-94, understand that your true AUD now aligns with your new program end date. You will enter your departure grace period immediately following your program end date.  
  • Page 2: Review the OPT recommendation and requested OPT start and end dates on page 2 of the I-20.  
• Print and sign your OPT I-20.  
  • You must sign the document by hand and in blue ink. The U.S. government does not permit students to sign the I-20 by digital or electronic means.  
• Scan and upload your signed OPT I-20 to your online OPT application (Form I-765) on the USCIS website.  
  • You must submit your complete online OPT application (Form I-765) to USCIS no later than 30 days from the “Date Issued” date on page 1 of your OPT I-20. Students who submit their application after this 30-day window will receive an OPT denial from USCIS.  
  • If you receive an OPT I-20 from ISEO but do not submit your OPT application to USCIS within 30 days, you must submit an Invalid OPT I-20 Replacement Request in iServices  to obtain a new OPT I-20 and restart the 30-day window. 

USCIS will process your OPT application according to their standard processing time, unless or until you pay for premium processing (Form I-907).  

USCIS will begin reviewing a student’s OPT application after the student has timely filed the online Form I-765 AND completed their Biometrics Appointment (if required). Processing time, whether standard or premium, does not begin until after the Biometrics Appointment (if required). 

Within 30 days of the date your Pre-Completion OPT I-20 was issued, submit your Form I-765 Application for Employment Authorization online, after creating an account on USCIS’ website.  

Important Reminders:  

• USCIS must receive your OPT Application no later than 30 days after ISEO issues your OPT I-20.  
  • Submit an Invalid OPT I-20 Replacement Request  in iServices if you need to restart the 30-day window.  
• USCIS must receive your OPT Application within the 90 days leading up to your requested OPT start date.  
• You must be physically present in the U.S. at the time you submit your OPT application (Form I-765) to USCIS.  
• USCIS operates on Universal Coordinated Time (UTC), which is different from Pacific Standard Time (PST) and Pacific Daylight Time (PDT). If you are filing close to any deadlines, ensure your application is complete and submitted before 11:59 PM UTC of the relevant day. If you are not sure how to determine the correct due date, please use a Universal Coordinated Time converter.   
• Mailing Address Tips: The U.S. mailing address you provide on your Form I-765 is where USCIS will send any response documents associated with your OPT application, including your I-797C Receipt Notice, any Requests for Evidence/Information (RFE/I), and your EAD card. Ensure you provide an address you will be able to regularly check in the months following your I-765 submission.  
• For USCIS form details, including filing tips and instructions, visit the USCIS website.  

I-797C Receipt Notice  

Within several weeks of receiving your Form I-765 OPT application, USCIS will mail you a receipt (Form I-797C) confirming they received your application. Keep this original receipt for your records. This is the only way you can track your application at the USCIS Service Centers.  

• Your receipt will be mailed to the mailing address you provided on your OPT application.  
• Your receipt will have a case number (beginning with three letters followed by 10 numbers). 

If you do not receive your I-797C Receipt Notice within 30 business days of filing your Form I-765, contact USCIS Customer Service to confirm your mailing address and request a replacement. USCIS may take longer than 30 business days to mail your I-797C, but it is important for you to receive this document.  

USCIS sometimes requires OPT applicants to appear in person for a Biometrics Services Appointment (fingerprints, photograph, brief interview, and/or signature) following their submission of the Form I-765. The appointment is to verify your identity, obtain additional information, and conduct background and security checks, including a check of criminal history records maintained by the Federal Bureau of Investigation (FBI)., before undertaking review of your application.  

Receiving your Biometrics Appointment Notice  

Within a few weeks of receiving your complete I-765, USCIS will inform you via an official notice if you are required to attend a Biometrics Appointment. The notice will provide you with the location of your local or designated USCIS Application Support Center (ASC), and the date and time of your appointment. The notice may come via:  

• email (the email you used for your I-765 application), OR  
• physical mail (via USPS to the address you provided in your I-765 application), OR  
• a message post in the Documents section of your USCIS Online Account.  

Please diligently check all three locations daily after you submit your Form I-765. It is your responsibility to attend your Biometrics Appointment as assigned to you, or otherwise timely reschedule it in your USCIS online account.  

If you fail to attend your Biometrics Appointment, USCIS will deny your OPT application.    

What to Expect at the Appointment  

ISEO recommends that you review your completed Form I-765 application before you go to your Biometrics Appointment. At your appointment, you will be required to sign an oath reaffirming that:    

• You provided or authorized all information in the application;    
• You reviewed and understood all the information contained in, and submitted with, your application; and    
• The information was complete, true, and correct at the time of filing.     

For more information, review USCIS’ website, Preparing for your Biometric Services Appointment.  

Working while Pending Pre-Completion OPT  

You may not begin working in the job you intend to undertake via Pre-Completion OPT until you have received your EAD card and your approved period of employment authorization has begun.  

While you await USCIS approval and your EAD card, you may:  

• Work on-campus, prior to the Program End Date on your Form I-20 or the Admit Until Date on your Form I-94, whichever is earlier  
• Work off-campus if authorized for CPT, up until the CPT end date on your Form I-20  
• Participate in volunteer opportunities  
• Research industries/companies and apply for jobs  

While you await USCIS approval and your EAD card, you may NOT:  

• Work off-campus in the position you intend to undertake while on Pre-Completion OPT  
• Work without receiving pay in a position that should receive payment (different than volunteer opportunities). For more information, review the U.S. Department of Labor’s Fair Labor Standards Act.   

Traveling while Pending Pre-Completion OPT  

ISEO advises that you not travel outside of the U.S. while your OPT application is pending. Travel presents immigration risk and may impact your OPT application. If you must undertake travel while pending OPT, please schedule an appointment with an ISEO Student Advisor before  you make travel plans.  

IMPORTANT! Remember, you must be physically present inside the U.S. when submitting your online Form I-765 OPT application, and to attend your Biometrics Appointment (if required). 

In some cases, USCIS may request additional documentation or information from you by mailing a Request for Evidence (RFE) or Request for Information (RFI) notice. USCIS may send an RFE/I to your mailing address (as indicated on your Form I-765), to your email (as indicated on your Form I-765), or to your USCIS online account. Make sure you are checking these locations diligently while you are pending OPT.   

USCIS may send you an RFE or RFI (RFE/I) for any of the following reasons:  

• You did not submit all the required evidence;  
• The evidence you submitted is no longer valid; and/or  
• USCIS needs more information to determine your eligibility for OPT.  

Receiving an RFE/I will delay the processing time of your OPT application.  

What to Do if You Receive an RFE/I  

• Read through the notice carefully and thoroughly! Take note of:  
  • The due date by which you must respond. You must respond to the RFE/I by this date, otherwise USCIS may deny your OPT application. ISEO recommends you respond to an RFE/I as quickly as possible.  
  • The method by which you must respond. An RFE/I may require you to mail your response back to USCIS, or direct you to upload documentation to your USCIS online account. You must follow the response directions exactly as USCIS has provided in the RFE/I notice, otherwise USCIS may deny your OPT application.  
  • The specific evidence or information being asked for. Depending on what USCIS is asking for, you may need to obtain information from different sources, if you do not already have the material(s) yourself. Some examples of the kinds of information USCIS may ask for includes, but is not limited to:   
    • Academic evidence or information: If USCIS is asking for academic material, such as your program study plan or research plan, or course syllabi, you may need to contact your major or academic department.  
    • Enrollment evidence or information: If USCIS is asking for enrollment material, such as official transcripts or enrollment verification, you may need to request documents from the Registrar’s office.  
    • F-1 status evidence or information: If USCIS is asking for material pertaining to your F-1 student status, such as proof of status maintenance, etc., submit a Letter Request in iServices to obtain immigration verification from ISEO.  
    • Employment evidence or information: If USCIS is asking for employment materials, such as past job offers or hours worked, etc., you may need to contact your past or present employer(s).  
    • Personal evidence or information: USCIS may also ask for material pertaining to personal information, such as past addresses where you have lived. 

Make sure you respond to the RFE/I with all requested information by the due date and via the method that USCIS has indicated in the notice. Failure to respond to the RFE/I exactly as requested may lead USCIS to deny your OPT application.  

Students may withdraw their OPT application after submitting the Form I-765, as long as USCIS has not yet issued a decision. To request a withdrawal of your OPT application, you must prepare a written statement outlining the reason for the request and a copy of your I-797C Receipt Notice. Withdrawal is at the discretion of USCIS and dependent on whether they can process your withdrawal request prior to completing review of your OPT application.  

If you need to withdraw your OPT application, please schedule an appointment with an ISEO Student Advisor.  

Note: All fees paid as part of the OPT application process are non-refundable if you choose to withdraw your application.  

OPT is a requestable benefit of F-1 status and is not guaranteed. USCIS may deny an OPT application at their discretion, including but not limited to, any of the following reasons:  

• The OPT application was missing required evidence or information, or was submitted incorrectly.  
• USCIS finds that the applicant has failed to maintain their legal U.S. status, past or present (including previous visa categories the individual may have visited the U.S. under).  
• USCIS finds the applicant ineligible for the requested OPT benefit, for any other reason.  

Many cases of OPT denial allow the applicant to apply for OPT again, however it is important to understand the reason for the denial before moving forward with a new application.  

If you receive an OPT denial or rejection notice from USCIS, please schedule an appointment with an ISEO Student Advisor. Be prepared to share a copy of the USCIS notice with the advisor during your appointment.   

I-797C Approval Notice  

If USCIS approves your OPT application, they will mail you an I-797C Approval Notice. Keep this approval notice for your records. The I-797C Approval Notice is not your employment authorization document; it is merely evidence that your request for OPT has been approved. The EAD card, which typically arrives at a later date, is the document required to begin work.  

Employment Authorization Document (EAD card)  

After USCIS approves your OPT application, they will print and mail your EAD card. You can expect to receive your EAD card at the mailing address you provided on your Form I-765 application approximately 2-4 weeks after your OPT is approved.  

You can begin your OPT employment once you have received your EAD card and the start date on that EAD card has arrived.