STEM OPT 24-month extension checklist

This page is part of the OPT and STEM OPT — complete guide cluster. It exists to answer the STEM OPT extension checklist decision. For E-Verify employer verification, read STEM OPT E-Verify requirements. For job changes during STEM OPT, read STEM OPT job change rules.

Who this is for

An F-1 OPT holder filing the 24-month STEM OPT extension (Form I-765 category (c)(3)(C)). This applies whether you are currently on standard post-completion OPT and approaching the EAD expiry date, or if you received your STEM degree and are planning ahead to ensure all three eligibility requirements are met before you start the filing process. Employers sponsoring STEM OPT employees will also find this page relevant for understanding their obligations under the I-983 training plan and E-Verify requirements.

If you need a broader overview of STEM OPT rather than the filing checklist, start with OPT and STEM OPT — complete guide. For employer-specific E-Verify verification, see STEM OPT E-Verify requirements.

The controlling source

Primary controlling source: 8 CFR § 214.2(f)(10)(ii)(C); § 214.2(f)(11).

Section 214.2(f)(10)(ii)(C) establishes the STEM OPT extension framework, authorising the 24-month extension for F-1 students who have completed a STEM designated degree program and are employed by an E-Verify enrolled employer. Section 214.2(f)(11) sets out the training plan requirements, reporting obligations, and the employer responsibilities that govern the extension period. Together, these regulations create a three-part test that must be satisfied before filing: a qualifying STEM degree, an E-Verify employer, and a signed I-983 training plan.

The three-part test

All three must be satisfied before filing:

1. STEM Designated Degree Program with correct CIP code. The degree must appear on the STEM Designated Degree Program List with a matching CIP code. The CIP code on the I-20 must match. A STEM subject degree from a non-listed CIP code does not qualify.
2. E-Verify employer. The employer that signs the I-983 must be enrolled in E-Verify under the correct employer name and EIN. A staffing agency that places the student at a non-E-Verify client typically does not qualify. Read STEM OPT E-Verify requirements for the employer-identity test.
3. Form I-983 training plan signed by both parties before training begins. The plan must include learning objectives, supervision structure, evaluation schedule, and compensation. Do not begin training before the plan is signed.

Documents that prove the case

Assemble the following before filing the I-765. USCIS may issue an RFE if any document is missing or inconsistent.

• Current OPT EAD — must still be valid at the time of I-765 receipt by USCIS. USCIS uses the receipt date, not the postmark date. If the EAD expires before USCIS receives your application, the STEM OPT extension is not available and you must depart or find another immigration option.
• STEM degree evidence — diploma or transcript showing the conferred degree and CIP code. If your degree program has changed CIP codes since you enrolled, confirm with the DSO which CIP code appears in SEVIS. The code on the I-20 must match the STEM Designated Degree Program List.
• I-20 with STEM recommendation from the DSO, issued within 30 days of the I-765 filing. The recommendation is entered in SEVIS by the DSO, and the page 2 printout includes the STEM OPT start date calculation and employer information.
• Form I-765 with category (c)(3)(C), properly completed with the correct eligibility code. Ensure the current EAD expiry date, the STEM degree information, and the employer details are correctly entered. A typo in the EAD expiry date can cause a rejection.
• Form I-983 signed by both student and qualifying supervisor before training begins. The supervisor must be an employee of the E-Verify-enrolled employer with direct oversight of the student’s training. A human resources representative may countersign, but the direct supervisor who completes the evaluations must also sign.
• E-Verify employer information — company legal name, EIN, and E-Verify company ID. Confirm these details by searching the employer’s name in the E-Verify database or ask the employer for their E-Verify enrollment confirmation letter. Using an incorrect EIN or company name can lead to an RFE or denial.

Timeline and key deadlines

• Before current EAD expires — file STEM OPT I-765. USCIS receipt must occur before the EAD end date. Filing 90 to 120 days before expiry is recommended to allow for processing delays. USCIS typically takes 3 to 5 months to adjudicate STEM OPT I-765 applications, so filing early prevents a gap in employment authorisation.
• Within 30 days of DSO recommendation — the I-765 must be received by USCIS. The DSO’s SEVIS recommendation is valid for 30 days only. If you do not file within this window, the DSO must re-enter the recommendation.
• Within 10 days of any change — report address, employer, or name changes to the DSO. The SEVP Portal allows self-service updates for address and employer information. Job changes require a new I-983 and DSO endorsement. Read STEM OPT job change rules.
• Every 6 months — validate employment and contact information through the SEVP Portal (6-month validation) and at the 12-month and 24-month marks complete the I-983 evaluation sections with your supervisor and submit to the DSO. Set calendar reminders 30 days before each deadline to avoid missed reporting windows.

Worked example

Employer E-Verify mismatch

A student has a qualifying STEM degree and a signed I-983 training plan. The employer uses a parent company’s E-Verify number, but the employing subsidiary is not separately enrolled in E-Verify under its own EIN. USCIS issues an RFE asking for proof that the employer signing the I-983 is the E-Verify-enrolled entity. The employer cannot produce the enrollment confirmation under the subsidiary’s EIN. The STEM OPT extension is denied. Confirm E-Verify enrollment by searching at e-verify.gov under the employer’s legal name and EIN before preparing the I-983. If the employer is enrolled under a parent company name, the I-983 signatory must be an employee of that parent company with direct supervisory authority.

Filing deadline scenario

A student’s post-completion OPT EAD expires on February 1. The student mails the STEM OPT I-765 on January 28, and USCIS receives it on February 2. Because the receipt date is February 2 — one day after the EAD expires — the application is rejected for untimely filing. The student has no cap-gap protection because no H-1B petition is pending. The student must depart the US or find another immigration option. The correct approach is to file by certified mail with delivery tracking and file at least 90 days before EAD expiry to allow for delivery delays.

Getting the DSO recommendation for STEM OPT

Before you can file the STEM OPT I-765, your DSO must recommend the extension in SEVIS and issue a new I-20 with the STEM OPT recommendation on page 2. To obtain this recommendation, you must submit to the DSO: a completed and signed Form I-983 training plan, evidence of the employer's E-Verify enrollment (E-Verify company ID or enrollment confirmation), and a completed STEM OPT request form if your school requires one. The DSO will review the I-983 to confirm the training plan is directly related to the STEM degree and that the employer-employee relationship is bonafide. The DSO may ask questions about the supervision structure or the learning objectives — respond promptly and provide any additional information requested. Once the DSO enters the recommendation in SEVIS, the I-20 with the STEM OPT recommendation is issued. The I-765 must be received by USCIS within 30 days of the DSO's recommendation date.

STEM OPT validation and reporting obligations

After the STEM OPT extension is approved, you must comply with ongoing reporting obligations. Every 6 months (on the anniversary of the STEM OPT start date and at the midpoint), you must validate your employment and contact information through the SEVP Portal or by contacting your DSO. The 6-month validation confirms that you are still employed, that the employer is still E-Verify enrolled, and that your address is current. At the 12-month and 24-month marks, you must complete the I-983 evaluation sections with your supervisor and submit the evaluations to the DSO. The 12-month evaluation assesses progress toward the training goals described in the I-983. The 24-month (final) evaluation assesses the overall training outcomes. Failure to complete any of these reporting requirements on time can result in SEVIS termination and loss of STEM OPT status. Track your reporting dates on a calendar with reminders set 30 days before each deadline.

Cap-gap protection during STEM OPT

If a STEM OPT holder is the beneficiary of a timely filed H-1B petition, cap-gap protection extends F-1 status and work authorization through October 1 of the H-1B start year. The cap-gap extension applies automatically when the H-1B petition is filed with a request for change of status. The STEM OPT EAD is extended through September 30 if the cap-gap overlaps with the STEM OPT period. However, cap-gap protection ends immediately if the H-1B petition is denied, revoked, or the student departs the US. During the cap-gap period, continue to meet STEM OPT reporting obligations. If the cap-gap extends beyond a required I-983 evaluation date, complete the evaluation on time despite the pending H-1B application. Read F-1 H-1B cap-gap extension guide for the full cap-gap rules.

What to do next

• Verify the employer with STEM OPT E-Verify requirements.
• Understand job-change rules at STEM OPT job change rules.
• Understand founder structures at STEM OPT self-employment and startups.

This guide is general information, not legal advice for your specific situation. A licensed attorney or regulated adviser should review your documents before you rely on a strategy or deadline.