What are the STEM OPT extension requirements for employers?
TL;DR: To sponsor a STEM OPT extension, an employer must be enrolled and in good standing with E-Verify, hold a valid EIN, jointly sign a Form I-983 formal training plan with the student, pay and treat the student comparably to similarly situated US workers, and report the student's termination or material job changes to the school's DSO — termination within 5 business days. Staffing and temp agencies generally can't qualify unless they're the entity actually delivering the training.
The claim
STEM OPT isn't just "OPT for two more years" — it comes with real compliance obligations on the employer side that don't exist for regular OPT, and USCIS/DHS can audit compliance with a site visit.
The evidence
USCIS's official STEM OPT extension page lists the employer requirements explicitly: E-Verify enrollment and good standing, a valid EIN, a formal Form I-983 training plan, reporting the student's termination or departure to the DSO within 5 business days, and providing pay/conditions commensurate with similarly situated US workers. DHS's Study in the States resources on Form I-983 confirm the joint student-employer completion requirement and the bona fide employer-employee relationship standard.
Employer requirements checklist
| Requirement | Detail |
|---|---|
| E-Verify enrollment | Must be enrolled and remain in good standing |
| Valid EIN | Required for tax/verification purposes |
| Form I-983 training plan | Jointly completed and signed with the student before the extension starts |
| Comparable treatment | Pay and conditions matching similarly situated US workers |
| Reporting termination | Must notify DSO within 5 business days of the student's departure |
| Reporting material changes | Modified I-983 submitted promptly for role/supervisor/site changes |
| Bona fide employer relationship | Cannot be "employer in name only"; no unpaid/volunteer roles |
Step by step
- Confirm E-Verify enrollment and good standing before agreeing to sponsor.
- Complete Form I-983 jointly with the student, documenting learning objectives and training structure.
- Submit I-983 to the student's DSO before the STEM OPT extension is requested/begins.
- Maintain the bona fide employer-employee relationship throughout — staffing/consulting arrangements face extra scrutiny.
- Report changes promptly — modified I-983 for material changes, DSO notification within 5 business days of termination.
FAQ
Can a small startup sponsor STEM OPT? Yes, as long as it meets E-Verify enrollment, has a valid EIN, and can genuinely provide the structured training described in the I-983 — company size alone isn't disqualifying.
Does DHS actually conduct site visits? Yes, DHS may conduct site visits at its discretion to confirm the employer has the resources and personnel to deliver the training described in the I-983.
What if the employer isn't E-Verified? The student cannot use that employer for a STEM OPT extension — E-Verify enrollment is a hard requirement, not optional documentation.
Can the training plan change after I-983 is submitted? Yes, but material changes must be reported via a modified I-983 to the DSO promptly; undisclosed changes risk the student's status.
By Pinal Dave Last updated: 2026-07-25