The Student and Exchange Visitor Program (SEVP), a component of U.S. Immigration and Customs Enforcement (ICE), issued Broadcast Message 2608-01 on August 12, 2026, and Broadcast Message 2608-02 on August 24, 2026, concerning Curricular Practical Training (CPT) authorization for F-1 students.
The guidance reiterates SEVP’s expectation that CPT be an integral part of an established curriculum and emphasizes the responsibility of Designated School Officials (DSOs) to ensure CPT employment authorizations comply with applicable regulations. Although the guidance does not amend the CPT regulations, it reflects a restrictive interpretation of what SEVP considers an “integral” component of an academic program and has prompted some institutions to review existing CPT policies and practices.
SEVP’s recent guidance underscores several key principles relating to CPT employment authorization for noncitizens in F-1 visa status.
CPT must be an integral component of an established curriculum
According to SEVP, CPT must be directly related to a student’s major area of study and serve a legitimate academic purpose rather than function primarily as a vehicle for employment. The guidance states that schools should be prepared to demonstrate that practical training is a core and essential component of the academic program and that the practical training requirement is academically justified.
Optional participation may not satisfy SEVP’s interpretation of CPT requirements
The August 24 guidance states that where participation in practical training is optional, the required and integral elements of CPT may not be satisfied. SEVP explains that when a course is elective and participation in CPT is therefore optional, CPT generally would not meet SEVP’s interpretation of an integral part of an established curriculum. The guidance further indicates that CPT should ordinarily be required for students enrolled in the relevant curriculum.
DSO certifications carry significant responsibility
SEVP reminds DSOs that certification of Form I-20 is made under penalty of perjury and requires school officials to attest that the information provided is true and correct to the best of their knowledge. According to SEVP, this responsibility includes ensuring that CPT authorizations are supported by the academic program and comply with governing regulations.
Reporting of suspected misuse
The guidance encourages reporting of suspected fraud, abuse, or misuse involving F-1 students or SEVP-certified schools through established SEVP reporting channels.
Potential consequences of improper CPT authorization
SEVP warns that improper CPT authorization may expose institutions and responsible officials to administrative or legal consequences. The August 12 broadcast message notes that noncompliance could affect a school’s SEVP certification and may create liability concerns where false certifications or inaccurate information are provided.
Although the guidance is directed primarily at educational institutions and DSOs, employers that hire F-1 students pursuant to CPT should not assume they are unaffected.
Historically, many employers have relied on universities and DSOs to evaluate whether CPT satisfies applicable regulatory requirements. The recent SEVP guidance signals that government agencies are placing greater emphasis on documentation, verification, and institutional accountability throughout the student visa process. As schools reassess CPT programs in light of SEVP’s interpretation, employers may encounter increased scrutiny of internship, cooperative education, training, and work-based learning arrangements that form the basis for CPT authorization.
Employers should anticipate questions from universities regarding the academic purpose of proposed assignments, the relationship of the work to the student’s field of study, supervision arrangements, worksite locations, and how the training supports program requirements. In some cases, educational institutions may pause, modify, or reevaluate existing CPT practices while they assess compliance with SEVP’s guidance.
A broader trend toward compliance oversight
The CPT guidance also arrives amid broader federal efforts to strengthen oversight of educational immigration programs.
Most notably, the Department of State recently proposed revisions to the J-1 Exchange Visitor Program regulations that would expand compliance obligations, strengthen program oversight, and reinforce reporting responsibilities associated with exchange visitor activities. While the proposal does not directly govern CPT authorization, it reflects a similar policy theme: heightened accountability for institutions and organizations that facilitate educational and training-based immigration programs.
For employers that host J-1 exchange visitors, the proposal serves as a reminder that program sponsors increasingly rely on host organizations to report and document material changes affecting exchange visitor training activities, work locations, supervision, compensation, and other significant program-related developments. In both the F-1 and J-1 contexts, federal agencies appear to be moving toward a model in which schools, sponsors, and employers are viewed as active compliance partners responsible for helping maintain program integrity.
Looking ahead
The August 2026 SEVP guidance does not amend the CPT regulation at 8 C.F.R. § 214.2(f)(10). However, it articulates a more restrictive interpretation of the longstanding requirement that CPT be an “integral part of an established curriculum.” As schools evaluate the practical implications of that interpretation, employers that rely on F-1 student talent should expect greater attention to the academic basis for CPT authorization and increased requests for supporting documentation.
At the same time, the State Department’s proposed J-1 regulatory changes suggest that enhanced oversight, reporting obligations, and accountability measures may continue to expand across educational immigration programs. Employers utilizing F-1 and J-1 talent should monitor these developments closely and review internal practices to ensure that training and employment arrangements remain consistent with evolving government expectations.
For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:
Angelo A. Paparelli
Partner, U.S. Immigration
Julie Guzman
Senior Associate
Stephanie Robayo
Manager
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