DHS to End Automatic EAD Extensions for Most Categories — No Impact on F-1 OPT or STEM OPT Students
The U.S. Department of Homeland Security (DHS) and U.S. Citizenship and Immigration Services (USCIS) have announced an interim final rule ending automatic extensions of Employment Authorization Documents (EADs) for most renewal applicants.
Beginning October 30, 2025, renewal applications for EADs will no longer qualify for the automatic 540-day extension previously available under 8 CFR 274a.13(d).
A few limited categories, such as certain Temporary Protected Status (TPS) holders, will continue to receive extensions where required by law or specific Federal Register notices.
What This Means
- EAD renewals filed on or after October 30, 2025 will not receive the 540-day automatic extension of work authorization.
- Individuals must have a newly approved EAD (or another valid work authorization) in order to continue employment after the current EAD expires.
- Renewal applications filed before October 30, 2025 will retain the automatic-extension coverage in effect at the time of filing.
Categories Most Likely to Be Affected at Penn
At the University of Pennsylvania, the groups most likely to be impacted by this change are:
- Individuals with EADs based on Adjustment of Status (AOS) applications (Form I-485 applicants), and
- H-4 dependents with EADs based on their spouse’s H-1B status.
At this time, there is no indication of change for J-2 dependents. J-2 EADs have not previously included an automatic extension period, and this DHS rule does not appear to alter that.
Important: F-1 OPT and STEM OPT Students Are Not Affected
This rule does not impact F-1 students on Optional Practical Training (OPT) or the 24-month STEM OPT extension.
- OPT has never included an automatic EAD extension.
- STEM OPT continues to include a 180-day automatic extension of work authorization for students who file a timely Form I-765 while their current EAD remains valid.
- This authorization is based on 8 CFR 274a.12(b)(6)(iv) and 8 CFR 214.2(f)(11)(i)(C), which are unchanged by the DHS rule.
Summary
While most EAD categories will lose the 540-day automatic-extension coverage for renewal applications filed on or after October 30, 2025, F-1 OPT and STEM OPT students are not affected. The most notable impacts at Penn are expected among individuals with Adjustment of Status (AOS) or H-4 dependent EADs.
Students and scholars are encouraged to review their specific EAD category and consult with ISSS if they have questions about how this rule may affect their work authorization or renewal timelines.