Navigating the Proposed Changes to F, J, and I Nonimmigrant Programs: What You Need to Know

On August 28, 2025, the U.S. Department of Homeland Security (DHS) unveiled a proposed regulation that could fundamentally reshape the F, J, and I nonimmigrant programs. This proposal marks a significant departure from the Trump administration’s 2020 attempt to overhaul these programs, which never came to fruition. The 2025 proposed changes introduce new requirements and restrictions that could impact international students, exchange visitors, and media representatives.

Key Highlights of the 2025 Proposed Regulation

Elimination of Duration of Status (D/S)
Currently, F (academic students), J (exchange visitors), and I (media representatives) nonimmigrants are admitted to the United States for the “duration of status” (D/S), allowing them to remain in the U.S. for as long as they maintain their program or status requirements. The proposed regulation would eliminate D/S and replace it with fixed admission periods, aligning these categories with other nonimmigrant visa classifications.

• F and J Nonimmigrants: Admission would be limited to the duration of their program, as indicated on Form I-20 (for F-1 students) or Form DS-2019 (for J-1 exchange visitors), or four years, whichever is shorter.
• I Nonimmigrants: Admission would be capped at 240 days.
• Extensions of Stay: Nonimmigrants needing to stay beyond their initial admission period must apply for an extension of stay through the U.S. Citizenship and Immigration Services (USCIS). F-1 students seeking extensions must demonstrate:
  • A compelling academic reason
  • A compelling medical reason
  • Circumstances beyond their control, such as natural disasters, national health crises, or institutional closures

Transition for Current Nonimmigrants
Upon implementation of the final regulation, all current F, J, and I nonimmigrants would transition from D/S to a specific expiration date. This shift could require proactive planning to ensure compliance with new deadlines.

Reduced Grace Period for F-1 Nonimmigrants
The proposed regulation shortens the departure grace period for F-1 students from 60 days to 30 days after program completion, requiring quicker action to either depart the U.S. or pursue lawful extensions or changes in status.

Biometric Requirements
F, J, and I nonimmigrants applying for extensions of stay may need to provide biometrics at a USCIS Application Support Center (ASC), adding a new layer of compliance to the process.

Changes to Optional Practical Training (OPT) for F-1 Students
F-1 students seeking post-completion Optional Practical Training (OPT) may need to file an extension of stay if their recommended OPT period extends beyond their I-94 expiration date. The proposal does not clarify whether the extension application and OPT Employment Authorization Document (EAD) can be filed concurrently, creating potential uncertainty for students planning their post-graduation employment.

Restrictions on English as a Second Language (ESL) Programs
F-1 students in ESL programs would be limited to an aggregate of 24 months of study, potentially impacting those enrolled in extended language programs.

Limits on Program and School Changes for F-1 Students
The proposed regulation imposes stricter rules on F-1 students’ ability to change schools, educational levels, or programs:

• Below Graduate Level: F-1 students cannot transfer schools, change educational levels, or switch programs within their first academic year unless the Student and Exchange Visitor Program (SEVP) approves the change as an “extenuating circumstance” and USCIS grants an extension of stay.
• Graduate Level and Above: F-1 students cannot change programs at any point during their studies.
• Completed Programs: F-1 students who complete a program at one educational level cannot start a new program at the same or lower educational level.
• Approval Process: Changes in educational objectives, previously approved by Designated School Officials (DSOs) via Form I-20, would now require USCIS approval through an extension of stay application.

Reinstatement and Extension Applications

• F-1 Nonimmigrants: Those needing reinstatement can file both a reinstatement application and an extension of stay application concurrently with USCIS.
• J-1 Nonimmigrants: Those approved for reinstatement by the U.S. Department of State (DOS) must file an extension of stay application with USCIS within 30 days of DOS approval.

H-1B Cap Gap Relief
The proposed regulation reaffirms H-1B Cap Gap relief for F-1 students, allowing them to extend their status through April 1 of the following year. It also introduces potential H-1B Cap Gap relief for J-1 nonimmigrants, pending publication of a notice in the Federal Register.

Public Comment and Implementation Timeline
DHS is accepting public comments on the proposed regulation through September 29, 2025. After reviewing feedback, DHS will issue a final regulation, which will take effect 30 days after publication, barring any court-ordered stays due to litigation. Stakeholders are encouraged to submit comments to influence the final rule’s outcome.

What This Means for You

The proposed changes introduce greater structure but also increased complexity for F, J, and I nonimmigrants. International students, exchange visitors, and media representatives may face stricter timelines, additional application requirements, and limited flexibility in their educational and professional pursuits. Failure to comply with these new rules could jeopardize lawful status in the U.S.