Pre-Completion Optional Practical Training

In order to be eligible for Pre-Completion OPT, you must:

• Have a current, valid Form I-20 reflecting your current field of study and education level
• Have a valid, unexpired passport
• Be in possession of a valid unexpired I-94 record of admission indicating you were admitted into the US in F-1 status
• Have been lawfully enrolled on a full-time basis for at least one full academic year (two consecutive semesters: Fall and Spring) prior to the requested employment start date
• Be currently maintaining valid F-1 student status and continuing toward the completion of your degree requirements (your requested Pre-Completion OPT end date must be on or before your program completion date)
• Have accumulated less than 12 months of full-time Curricular Practical Training (CPT) at your current degree level
• Obtain an updated Form I-20 from ISS showing Pre-Completion OPT Requested on page 2 before filing Form I-765 with USCIS
• Be physically present in the United States when you file Form I-765 with USCIS

Enrollment & Work Hour Limitations

Pre-Completion OPT has strict limits on work hours and location depending on the academic term:

Note for Thesis-Option Master’s and Doctoral Students: If you have completed all required coursework (excluding thesis/dissertation credit hours) and are only working on your thesis or dissertation, consult an ISS Student Counselor regarding your eligibility for either Pre-Completion or Post-Completion OPT.

Impact on Post-Completion OPT Eligibility

F-1 students are allotted a total of 12 months of standard OPT per higher degree level. Any period of approved Pre-Completion OPT is deducted from your available Post-Completion OPT benefit:

• Part-Time Pre-Completion OPT (20 hours/week or less): Deducted at a 50% rate (e.g., 4 months of approved part-time Pre-Completion OPT reduces your available Post-Completion OPT by 2 months, leaving 10 months after graduation).
• Full-Time Pre-Completion OPT (more than 20 hours/week): Deducted at a 100% rate (e.g., 3 months of approved full-time Summer Pre-Completion OPT reduces your available Post-Completion OPT by 3 months, leaving 9 months after graduation).

Even at the reduced part-time rate, Pre-Completion OPT uses employment authorization time that many students prefer to save for after graduation. Once USCIS approves your Pre-Completion OPT and issues your EAD card, that time is deducted regardless of whether you actually find a job or work during the authorized period.

USCIS Processing Risks & Adjudication Concerns

• Historical Processing Pauses: Students should be aware that in Summer 2025, USCIS paused the adjudication of Pre-Completion OPT applications for several months without formal explanation. Currently, it remains unclear why this pause occurred or whether USCIS will maintain consistent, regular processing timelines for Pre-Completion OPT requests in future peak seasons.
• No Automatic Cap-Gap or Extension Benefit: Pre-Completion OPT ends strictly on the expiration date printed on your EAD card. If you plan to work after graduation, you must submit a separate application (and pay a separate filing fee) for Post-Completion OPT within the standard Post-Completion filing window.

Timing is critical when planning for Pre-Completion OPT:

• Earliest Time to File with USCIS: USCIS allows Pre-Completion OPT applications to be filed no more than 90 days before the intended employment start date. (Provided you have already completed one full academic year; if you are in your first academic year, you cannot file earlier than 90 days before the completion of your full academic year.)
• Within 30 Days of ISS I-20 Issuance: USCIS must receive your Form I-765 application within 30 days of the date the ISS Immigration Counselor recommends Pre-Completion OPT in SEVIS and signs your Form I-20.
• USCIS Processing Times: Standard USCIS processing time for Form I-765 is typically 3 to 5 months. To check current USCIS processing estimates, visit When to Apply for OPT | ISS>USCIS Processing Times.
• Premium Processing: Because USCIS only allows you to file up to 90 days before your requested start date—while standard processing often takes 3 to 5 months—students applying for Pre-Completion OPT frequently need to consider paying an additional fee for Premium Processing Service (uscis.gov) to increase the likelihood of obtaining approval by their desired start date.
• Strict Start Date Rule: Employment cannot begin while your application is pending. You may only begin working after USCIS approves your application, you have your physical EAD card in hand, and the approved start date printed on your EAD card has arrived.

Pre-Completion OPT follows the same request workflow in MyISS as Post-Completion OPT. You must obtain an updated Form I-20 from ISS showing Pre-Completion OPT requested on page 2 before submitting Form I-765 to USCIS.

Step 1: Discuss Your Plans with Your Academic Contact

Before submitting an application, discuss your internship/employment opportunity and academic schedule with your academic department to confirm that the work is directly related to your major field of study and will not interfere with your full-time enrollment requirements. See Academic Contacts | ISS for guidance on identifying your department's designated contact.

Step 2: Submit the OPT I-20 Request E-Form Group in MyISS

Log in to MyISS using Full Client Services for Students & Scholars and navigate to:

MyISS > F-1 Optional Practical Training > Post-Completion OPT Recommendation I-20 Request

1. Complete the OPT Online Workshop and Quiz
2. Review the OPT Application Document Instructions e-form.
3. Complete the OPT Statement of Understanding e-form.
4. Complete the OPT Application Document and Information Verification e-form.
   • CRITICAL INSTRUCTION FOR PRE-COMPLETION OPT:
     • In this final e-form, enter your requested start and end dates (which will be for less than 12 months of authorization and prior to your graduation date) and explicitly state in the comment boxes that you are applying for Pre-Completion OPT (specifying whether you are requesting Part-Time or Full-Time authorization).
     • Upload the required digital documents (draft Form I-765, valid passport biographical page, and most recent I-94 record).

Once you submit the final e-form, your designated Academic Contact will be notified by email to complete their verification portion. After your Academic Contact submits their form, your request is routed to ISS.

ISS Processing Time

ISS processing time is up to 14 calendar days (10 business days) from the date your Academic Contact completes their portion. ISS cannot accommodate expedite requests.

Step 3: Receive Your Pre-Completion OPT I-20

Once your eligibility is verified, an ISS Immigration Counselor will issue a new Form I-20 showing Pre-Completion OPT Requested (with your requested dates and part-time/full-time notation) on page 2 of your I-20 and email you with final instructions. Print the I-20 and sign it by hand (a "wet signature") before filing with USCIS.

Because the USCIS Form I-765 filing requirements, document checklists, and government filing fees are identical to Post-Completion OPT (except that you will use the Pre-Completion OPT eligibility category (c)(3)(A) on Form I-765 instead of (c)(3)(B)), please visit our main Optional Practical Training | ISS and review the following sections for detailed step-by-step instructions:

• How to File with USCIS (Filing Online via MyUSCIS vs. Filing by Mail, required documents, passport photo specifications, and UTC timezone rules).
• What Happens After I apply for OPT? (Tracking your I-797 Receipt Notice, responding to a Request for Evidence [RFE], being notified of and attending your in-person biometrics appointment (uscis.gov), and receiving your EAD card).

Key Differences to Remember for Pre-Completion OPT

• Form I-765 Eligibility Category: Ensure you select or enter category (c)(3)(A) (Pre-Completion OPT) on Form I-765. Entering the wrong category code can result in a denial or forfeiture of your filing fee.
• No 90-Day Unemployment Clock: The 90-day unemployment limit applies only to Post-Completion OPT. While you do not accrue "unemployment days" during Pre-Completion OPT, any authorized time on your Pre-Completion EAD card is still permanently deducted from your 12-month Post-Completion OPT allotment whether you work or not.

Maintaining Student Status

While on Pre-Completion OPT during Fall and Spring semesters, your primary purpose in the US remains being a full-time student. You must continue to meet all standard F-1 enrollment and physical presence requirements.

Uploading Your EAD & Reporting Changes

Once you receive your Receipt Notice, Approval Notice, or EAD card, upload a copy via MyISS > F-1 Optional Practical Training > Upload an OPT-Related Document.

Update your Address, If Needed

Any changes to your U.S. residential address must be reported within 10 calendar days via MyISS > F-1 and J-1 Student Services > Address Update (U.S. Residential).

Travel Abroad

Because you are still an active, enrolled student prior to your I-20 program end date, travel signatures on your Form I-20 remain valid for one year (unlike Post-Completion OPT, where travel signatures are valid for six months). Carry your valid passport, valid F-1 visa, and signed I-20 when re-entering the US. More info on F-1 Travel Abroad | ISS

If you have questions about whether Pre-Completion OPT is the right choice for your academic and career goals, please Contact Student Services | ISS to connect with an ISS Student Immigration Counselor.

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