The OPT filing window: 60 days became 30 on September 15, 2026

Students still search for "the 60-day OPT filing window," and for years that was the right number. It isn't anymore. The DHS final rule that ended duration of status also shortened the post-completion OPT filing window: as of September 15, 2026, USCIS must receive your Form I-765 no later than 30 days after your program end date. 8 CFR 214.2(f)(11)(i)(B)(2), as amended by 91 FR 44976 (amendatory text at 91 FR 45124)

So: can you file 45 days after graduation? It depends on one date: when USCIS receives your application. Received on or before September 14, 2026, the old 60-day window applies and a day-45 filing is timely. Received on or after September 15, 2026, the 30-day limit applies and day 45 is too late. Applications already pending with USCIS on September 15, 2026 remain valid. 8 CFR 214.1(m)(2); amended 214.2(f)(11)(i)(B)(2)

The three deadlines that govern your filing now

1. The filing window. USCIS must receive your Form I-765 no earlier than 90 days before, and no later than 30 days after, your program end date — the end date on your I-20, not your ceremony date. The 90-day opening is unchanged from the old rule; only the closing moved. 8 CFR 214.2(f)(11)(i)(B)(2)
2. The 30-day SEVIS rule. Separately, USCIS must receive the I-765 within 30 days of the date your DSO enters the OPT recommendation into SEVIS. This rule did not change — but it now runs alongside a filing window of the same length, so a recommendation that sits while you gather documents burns time you no longer have. 8 CFR 214.2(f)(11)(i)(A)
3. The requested start date. Your requested OPT start date can be at most 30 days after your program end date — this cap was also 60 days before the rule change. You choose it on the I-765; you cannot push it later to wait out slow processing. 8 CFR 214.2(f)(11)(i)(D)

What this means in practice

File early. The window opens 90 days before your program end date, and there is no advantage to waiting. Under the old rule, a student who missed graduation-season paperwork had two months to recover. Now the recovery period is one month, and the SEVIS-recommendation clock runs inside it. The safe pattern is simple: ask your DSO for the OPT recommendation before your program ends, file online the day you have it, and request a start date no later than 30 days after your program end date.

If USCIS approves after your requested start date, you do not lose eligibility — employment authorization begins on the approval date shown on the EAD. What you lose is usable OPT time, since the authorized period still ends when it ends. That is one more argument for filing at the early edge of the window. 8 CFR 214.2(f)(11)(i)(D)

The March 18, 2027 carve-out — what it does and doesn't do

Under the new rule, applying for OPT generally also means filing a Form I-539 to extend your fixed period of stay. There is a transition carve-out: a student who files for OPT on or before March 18, 2027, while still within their period of admission, does not need the I-539 that the rule change would otherwise require. 8 CFR 214.1(m)(1)(i)

Read that carefully. The carve-out removes a form; it does not extend a deadline. Your I-765 must still reach USCIS within 30 days of your program end date. March 18, 2027 is not a filing window — it is a cutoff for skipping the I-539. Full details in the March 18, 2027 guide.

What you cannot do

• Work while the application is pending. Post-completion OPT requires the approved EAD in hand and its start date reached. This did not change.
• File after day 30. Even one day late, USCIS will deny. At that point the realistic paths are a new program of study or departure; talk to your DSO before doing anything.
• Let the SEVIS recommendation age past 30 days. Your DSO can generally refresh an expired recommendation — but that costs days, and the window no longer has spare ones.

Which window governs your filing

The line is the receipt date, not your program end date: applications USCIS receives before September 15, 2026 are judged under the old 60-day window, and applications pending on that date remain valid (8 CFR 214.1(m)(2)). Applications received on or after September 15, 2026 fall under the 30-day limit — the rule has no savings clause for a window that straddles the effective date. If your old-rule window is open and you have not filed, file before September 15; if you are reading this after that date, assume the 30-day limit and talk to your DSO today.

A note on "graduation" vs. your program end date

The clock runs from the program end date your DSO records in SEVIS — usually the last day of your final term. If you finished coursework in December but the degree confers in May, the SEVIS end date is what counts. When those dates don't line up, that's a conversation with your DSO before you file, because the answer changes the whole calendar — and with a 30-day window, there is no room to discover it late.