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• New F-1 Rule Changes Grace Periods for OPT and Status Extensions
• USCIS Takes First Step Toward Mandatory Electronic Filing
• DHS Expands 9-11 Response Fee to H-1B and L-1 Extensions
• USCIS Extends Somalia TPS Work Authorization Through August 12
• Singapore Releases New COMPASS Salary Benchmarks for Employment Passes

New F-1 Rule Changes Grace Periods for OPT and Status Extensions

DHS’s new rule eliminating Duration of Status will significantly change how F-1 students maintain status during and after Optional Practical Training. Under the current framework, students generally receive a 60 day grace period after completing their program or authorized practical training. USCIS also provides certain post denial protections when an OPT or STEM OPT application is denied. 

Under the new fixed admission framework, the standard F-1 departure period will be shortened to 30 days. More importantly, OPT will become tied to the student’s fixed period of admission and, when necessary, an approved extension of stay. 

This creates several important distinctions: 

• Program or OPT completion: Students generally receive a 30 day period to prepare for departure. 

• OPT or STEM OPT denial: The current special 60 day post denial framework will no longer operate in the same way. Students must instead look to their remaining authorized admission period and any associated extension of stay. 

• Extension denied after status expires: If USCIS denies an extension after the student’s authorized admission period has already expired, the student and dependents generally must depart immediately. No additional post denial grace period applies. 

The rule therefore makes the expiration date on Form I-94 significantly more important for students, universities, and employers. 

DHS has also established special transition provisions for certain post completion OPT and STEM OPT cases during the first six months of implementation, meaning cases filed around the effective date will require separate analysis. 

Impact: The new framework leaves less room for error when OPT, STEM OPT, or an extension of stay is pending. Employers and students should closely track I-94 expiration dates and begin extension planning early, as a denial after the authorized stay expires could result in immediate departure and potential employment interruption.

USCIS Takes First Step Toward Mandatory Electronic Filing

U.S. Citizenship and Immigration Services (USCIS) has issued a new interim final rule giving the agency authority to require electronic filing for certain immigration benefit applications and petitions. The rule took effect August 11, 2026 and represents another step in USCIS’s transition from paper based processing toward a more digital immigration system. 

Importantly, USCIS has not yet designated any specific form for mandatory electronic filing. Before requiring a form to be filed electronically, USCIS must generally make that form available for electronic filing for at least 180 days and provide the public with at least 60 days’ advance notice of the mandatory filing requirement. 

USCIS currently offers voluntary electronic filing for a limited number of immigration forms and case types, including certain Form I-129, I-140, I-485, I-765, I-90, and N-400 filings. Depending on the benefit request, applicants may complete the form online or upload a completed PDF through a USCIS online account. 

The rule also establishes a process for requesting waivers when an individual cannot reasonably comply with mandatory electronic filing. DHS states that expanded electronic filing is intended to improve processing efficiency, reduce reliance on paper files, and strengthen immigration system integrity. 

Public comments on the interim rule will be accepted through October 13, 2026. 

Impact: There is no immediate change to how employers or applicants must file specific forms. However, organizations with high immigration filing volumes should prepare for a gradual shift toward mandatory electronic submissions and monitor USCIS announcements identifying which forms will transition first.

DHS Expands 9-11 Response Fee to H-1B and L-1 Extensions

The Department of Homeland Security has finalized a rule expanding the 9-11 Response and Biometric Entry Exit Fee to additional H-1B and L-1 petitions. The change will require certain employers to pay the supplemental fee when filing any extension of stay petition, not just initial or change of employer cases. 

The rule applies only to employers that: 

• Employ at least 50 individuals in the United States 

• Have more than 50 percent of their U.S. workforce in H-1B, L-1A, or L-1B status 

For employers meeting both thresholds, the additional fee is $4,000 for H-1B petitions and $4,500 for L-1 petitions. Current USCIS materials confirm these fee amounts and the employer thresholds. 

Previously, the fee generally applied when the employer was also required to pay the Fraud Prevention and Detection Fee, such as for an initial H-1B or L-1 grant or a change of employer. The new regulation expands the requirement to extension petitions regardless of whether the fraud fee applies. Amended petitions that do not request an extension of stay remain exempt. 

The fee was established by Congress to support biometric entry and exit programs. Unless Congress acts to extend it, the statutory fee is currently scheduled to sunset on September 30, 2027. 

Impact: The expansion will substantially increase extension costs for employers subject to the 50 50 rule, particularly organizations with large H-1B and L-1 populations. Affected employers should incorporate the additional fees into immigration budgets and identify upcoming extension filings that will become subject to the new requirement.

USCIS Extends Somalia TPS Work Authorization Through August 12

U.S. Citizenship and Immigration Services (USCIS) has issued another brief extension of employment authorization for certain Temporary Protected Status (TPS) beneficiaries from Somalia. Eligible Employment Authorization Documents will now remain valid through August 12, 2026, extending the previous expiration date of August 10. 

The automatic extension applies to Somalia TPS EADs with original expiration dates of March 17, 2023, September 17, 2024, or March 17, 2026. Eligible beneficiaries may continue relying on these documents as evidence of employment authorization during the extended period. 

USCIS has issued a series of short extensions as litigation surrounding Somalia’s TPS designation continues. These developments follow the Supreme Court’s June 2026 decision allowing the Administration to proceed with TPS terminations for Haiti and Syria. That ruling has affected ongoing litigation involving several other TPS designations, including Somalia. 

The repeated short term extensions have created a rapidly changing compliance environment for employers. Organizations with Somalia TPS beneficiaries should regularly review USCIS guidance rather than relying on previously calculated expiration dates, as work authorization periods may change with little advance notice. 

Impact: The latest extension preserves employment authorization for eligible Somalia TPS beneficiaries through August 12, but provides only short term certainty. Employers should closely monitor USCIS updates and maintain accurate Form I-9 records as litigation continues and additional changes to employment authorization may follow. 

Singapore Releases New COMPASS Salary Benchmarks for Employment Passes

Singapore’s Ministry of Manpower has released its next salary benchmarking table under the Complementarity Assessment Framework, or COMPASS, which evaluates Employment Pass applications through a points based system. The updated benchmarks will apply to new Employment Pass applications beginning January 1, 2027 and renewal applications for passes expiring from July 1, 2027. 

Under COMPASS, salary is one of several criteria used to determine whether an applicant qualifies for an Employment Pass. The C1 salary criterion compares an applicant’s fixed monthly salary against salaries of local professionals in the same sector and age group. 

Depending on the applicable benchmark, an applicant may receive: 

• 20 points for meeting the highest qualifying salary benchmark 

• 10 points for meeting the intermediate benchmark 

• No C1 points if the salary falls below the applicable threshold 

Applicants generally need at least 40 COMPASS points overall to qualify for an Employment Pass, meaning employees who receive no salary points may still qualify by earning sufficient points under other criteria. 

The current salary benchmarks remain applicable to new applications filed through December 31, 2026 and renewals for passes expiring through June 30, 2027. Employers should therefore confirm which benchmarking table applies based on the filing or expiration date before assessing eligibility. 

Impact: Employers sponsoring Employment Pass holders should begin reviewing salaries against the 2027 benchmarks well before they take effect. Employees who no longer earn sufficient C1 points may require compensation adjustments or stronger scores elsewhere under COMPASS to remain eligible for a new or renewed Employment Pass.