Here's how it plays out for students who are physically in the U.S. on D/S when the rule takes effect on September 15, 2026 — this is the transition framework in new 8 CFR 214.1(m):

Your D/S admission converts automatically — no form, no fee. If you're validly maintaining F-1 status on September 15, 2026, your authorized stay simply becomes the program end date on the Form I-20 that's valid on that day, capped at 4 years from the effective date (so no later than September 15, 2030), plus 60 days to depart. Notably, the transition lets current students keep the old 60-day grace period; only newly admitted students get the reduced 30-day period. J-1s convert the same way but get 30 days.

If your program fits within that window, nothing changes day-to-day. Most students will simply finish their program under their existing I-20 end date. DHS expects the majority of F-1s (bachelor's and master's students, ~79% of the population) to complete within 4 years.

If you need time beyond your I-20 end date (or the 4-year cap), you must now file an EOS with USCIS. A DSO program extension alone no longer extends your stay — the DSO only recommends the extension on your I-20, and you then file (anticipated Form I-539) with the fee and biometrics before your authorized period expires. This applies to continuing your program, starting a new one, or doing practical training. PhD students and others in programs running past September 2030 will hit the 4-year cap and need an EOS even if their I-20 shows a later date.

Travel resets you to the new regime. The moment you depart and re-enter after September 15, 2026, CBP admits you like any new student: fixed period based on your I-20 end date, with the 30-day (not 60-day) departure period. So the 60-day transitional grace only survives as long as you don't leave the country.

OPT applicants get a special reprieve. If you timely file your post-completion OPT or STEM OPT application on or before September 15, 2026, you do not have to file an EOS — just the I-765. DHS can extend this exemption in 6-month increments by Federal Register notice. If you leave the U.S. and come back before filing, though, you'll need to file both the I-765 and an I-539.

Pending employment-authorization applications are protected. If your OPT/STEM EAD application is pending on the effective date, you may lawfully remain while it's decided. If approved, you're authorized through the EAD expiration + 60 days; if denied, through your I-20 program end date + 60 days, as long as you keep pursuing a full course of study. Other (non-OPT) pending EAD applications work similarly — no refiling needed.

A few important consequences to internalize:

• Unlawful presence now runs on autopilot. Once your converted admission period ends, unlawful presence accrues the day after — no formal government finding needed, unlike under D/S. Overstaying can trigger the 3- and 10-year bars.
• The new study restrictions apply prospectively. Programs you completed before September 15, 2026 don't count against the new prohibition on same-level/lower-level programs — so someone who finished a master's before the effective date could still enroll in a second master's. Anything completed after the effective date counts.
• The transition doesn't cover everyone. It excludes students who are outside the U.S. on the effective date (they're simply admitted under the new fixed-period rules on entry) and anyone already in violation of status.

The practical takeaway: find the program end date on your current I-20 — that date (or September 15, 2030, whichever is earlier) is now effectively your I-94 expiration plus 60 days, and every plan (graduation, OPT, a new degree, travel) should be built around it.