A preliminary injunction is a formal request asking a court to issue a temporary order early in a lawsuit – before the case is fully decided – to require someone to do something, or, as in in this case, to stop doing something. The goal of this filing is to compel the government to halt its implementation of the rule replacing D/S with a fixed visa permission of up to four years. After the limit is reached, students and visitors must apply for an extension to US immigration authorities. The final rule is meant to come into effect on 15 September 2026.

Parties to the legal challenge are:

• NAFSA: Association of International Educators
• The Presidents’ Alliance on Higher Education and Immigration
• The Association of Independent Colleges and Universities in Massachusetts (AICUM)
• The American Federation of Teachers (AFT)
• Graduate Labor Organization, AFT Local 6516 (GLO)
• International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)
• United Auto Workers Local 2322
• The NewsGuild-CWA

“Ending Duration of Status and imposing new limits on academic decision-making is a solution in search of a problem,” said NAFSA CEO and executive director Dr Fanta Aw. “The rule will severely undermine the contributions international students make to US campuses, economies, and national security. After carefully reviewing the final rule and the sweeping harm it will cause to our national interest, it is clear that litigation is warranted and necessary.”

McDermott Will & Schulte will represent the plaintiffs in the U.S. District Court for the District of Massachusetts.

Background

The D/S system was in place for decades, and it allowed international students to stay in the US to complete their full academic programme as well as to gain three years of post-study work experience. For more background on what the end of D/S means for students, universities, and businesses, please see our comprehensive article here.

Miriam Feldblum, president and CEO of the Presidents’ Alliance on Higher Education and Immigration says:

“This rule upends the longstanding Duration of Status framework that has allowed international students and scholars to pursue their educational programs while maintaining lawful status. By placing time limits that do not align with actual program lengths or students’ educational needs and shifting crucial academic decisions from institutions to immigration officials, the rule will disrupt educational pathways, impose significant new burdens on colleges and universities, and make the United States less competitive as the premier destination for global talent. We are going to court to protect international students and scholars and to defend our member institutions’ ability to educate, train, and retain them.”

What is the basis for the challenge?

The consortium argues: “The final rule violates the Administrative Procedure Act because DHS failed to adequately assess its costs and benefits, meaningfully respond to public comments, consider less burdensome alternatives, or justify the rule based on its stated objectives. It also alleges that DHS provided an inadequate public comment period and exceeded its statutory authority.”

“The United States once again is breaking the law for its own political purposes and, in doing so, is hurting Americans and American enterprise,” argues AFT President Randi Weingarten. “And it’s using international students – who we’ve welcomed here to help us – as its pawns. America is a leader in cutting-edge research because generations of scientists from every corner of the globe have been free to pursue difficult questions, challenge conventional wisdom, collaborate openly and publish their findings – without political interference. This latest assault on knowledge by the Trump administration arbitrarily limits how long international scholars have to complete their studies and risks turning a welcoming environment for students into a hostile one. We stand united with our higher education members, international and American alike, so they can continue to make US colleges and universities the envy of the world.”

What is at stake?

The plaintiffs explain: “These changes will create significant uncertainty and administrative burdens for international students and exchange visitors and the institutions that support them. They will also interfere with academic decision-making, disrupt students’ educational and professional plans, and undermine the ability of U.S. colleges and universities to attract and retain global talent.”

Robert McCarron, president and CEO of the Association of Independent Colleges & Universities in Massachusetts, comments:

“More than 80,000 international students come to Massachusetts to pursue higher education, adding vibrancy and innovation to our campuses and often founding startups in Massachusetts. These students and researchers drive innovation, pursue life-changing research, and create more than $4 billion annually in economic impact in Massachusetts. The litigation seeks to ensure that such profound changes to the rules governing international students and others comply with applicable legal requirements and reaffirms that Massachusetts continues to welcome talented students and researchers from across the globe.”

What happens next?

Legal observers expect that the court will take up the coalition’s request for emergency relief, which, if successful, would prevent the rule from coming into effect on 15 September.

The immigration law firm Fragomen notes in its guidance that, “Prospects for the lawsuit are uncertain, and employers and foreign nationals should continue to prepare for the scheduled implementation of the new regulation on September 15 in the event the plaintiffs’ efforts to obtain an emergency stay are unsuccessful.”

For additional background, please see:

• “Updated: US Department of Homeland Security publishes rule to end Duration of Status for international students”

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• Anxious, including about AI’s impact on their career;
• Considering a wider range of study abroad options, and carefully evaluating risk and reward.

The survey for the report was completed by 870 education agents across 64 countries in May 2026.

What are the issues?

The last time international students felt this stressed about their education was arguably during the COVID-19 pandemic. Study plans were disrupted; isolation was the norm; and worries about personal health and family members’ health was intense.

Students’ concerns are different today. Many of them stem from an uncertainty about how to make wise decisions about what to study and where to study.

Surveyed agents said that students are most concerned about (1) the risk of sudden changes to visa rules and (2) cost of living pressures. Agents have to advise students about whether a Big Four destination (i.e., Australia, Canada, the UK, and the US) has changed its immigration settings yet again.

The continued narrowing of visa and immigration rights – with new rules often announced without warning – provides ample evidence that there is more risk to choosing these destinations than in the past.

Significant proportions of agents also said that students are worried about safety and security, exchange rate volatility, risk of travel disruption, increased cost of air travel, breakdown in country-to-country relations, and rising fuel and energy costs.

Students need more support

More than half of agents said that compared with 12 months ago, students are more likely to face financial strain (54%), need more academic support (78%), and need more mental and social support (82%). All of these percentages increased markedly since the previous survey in 2025.

A growing body of US, UK, and global shows that large proportions of youth believe that AI is a threat to their job prospects. This is reinforced in the Navitas survey: 75% of agents said that students are concerned about the impact of AI on their careers.

Visa acceptance rates are deterring even the strongest students

In emerging markets, students are well aware that visa rejection rates are high in the Big Four. Agents said this awareness is reducing applications even from top students with a good chance of being approved (80%). Another 76% said that students with strong academic and financial profiles are more likely to choose alternative destinations with higher visa certainty.

Increased interest in alternative destinations, more questions about the value of study abroad

International students are reacting in a variety of ways to the more uncertain climate around study abroad and to affordability pressures:

• 82% of agents said applicants are applying to more destination countries than in the past;
• 85% said they are applying to more institutions within each destination country;
• 77% said they are increasingly applying to study in alternative destinations;
• 72% said they are more likely to have a back-up plan to study in their home country;
• And 68% said that they are more likely to give up on study abroad due to lack of affordability

Study at home is increasingly an option

Close to half of agents said that there is now a perception that universities or branch campuses in their country are providing an equal quality of education as institutions overseas. Among students who decide to stay home, affordability is by far the top reason (87%).

Destination trends

Perceptions of top anglophone destinations have stabilised for Australia, picked up for Canada, and are continuing to slide in the UK. New Zealand is by far outperforming the Big Four in terms of positive perceptions, while the US has the poorest image.

AI is not displacing agents

AI may be changing the nature of student–agent interactions, but it is not substituting for agents’ skills and human assistance. Students are consulting AI when researching study abroad and then going to agents to validate/interpret the information. Over 4 in 10 agents said that students are relying on them more despite AI, and 3 in 10 said there has been no change.

In the foreword to the survey report, Scott Jones, group CEO of Navitas, contextualised the findings and the importance of hearing from agents:

“Once again, the results offer compelling data that both confirms the behaviours we are seeing, and sheds light on how the international education landscape continues to evolve in the current economic and geopolitical environment.”

There is clearly a new competitive advantage for destinations and institutions that can access it: certainty. Communicating stable visa policies, strong student supports, programme strengths, and in-study and post-study work opportunities can go a long way toward emphasising this advantage.

For additional background, please see:

• “���Ϲ��� Podcast: Student flows are shifting. Are agencies following suit?”
• “Visa delays and policy uncertainty projected to reduce foreign enrolment in the US by more than 100,000 students this fall”

The post Global agent survey reveals international students’ top concerns are visa uncertainty and affordability appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

They are Bridge Mills Galway Language Centre, Emerald Cultural Institute, International House Dublin, Liffey College, and Patrick’s English Academy.

Those five schools now join that have to date also been awarded the mark.

The announcement of the first language school awards, said Dr Lynn Ramsey, CEO of QQI, “marks a new era of quality oversight and regulation for the English-language education sector in Ireland, with the establishment of formal, statutory engagement with QQI. Under the scheme, QQI has a statutory monitoring responsibility to ensure providers adhere to the agreed code of practice, ultimately ensuring that the rights of learners are protected during their time studying in Ireland.”

An accompanying statement from QQI provides important background: “To obtain TrustEd Ireland authorisation, [ELT] providers must undergo a thorough due diligence assessment, which examines areas such as financial and legal structures and business plans to establish the capacity and capability of private education providers to deliver quality assured education programmes.

“Under the scheme, providers must also have quality assurance procedures that are approved by QQI and demonstrate compliance with an associated Code of Practice.” (Note that there are distinct Codes of Practice for and for .)

Replacing the ILEP

The continued expansion of the TrustEd Ireland scheme has additional significance beyond its role as an official quality mark. First, the provisions for the mark are enshrined in Irish legislation. QQI’s powers to assess and monitor providers and to enforce the requirements of the scheme also arise from that legislation.

Second, the TrustEd Ireland mark will shortly become the basis for determining whether or not an Irish institution or school is eligible to recruit non-EU students. In other words, it functions as a licence to operate in the international student market, at least in terms of recruitment of non-EU/EEA students that require a visa to study in Ireland.

The current mechanism for this is the Interim List of Eligible Programmes (ILEP), which is maintained by the Department of Justice’s Immigration Service Delivery. The ILEP, however, will shortly be superseded by the TrustEd Ireland scheme.

First announced in 2024, an initial window for applications for the TrustEd Ireland mark opened from 14 October 2024 to 28 March 2025. A second window was opened from 13 October 2025 to 27 March 2026, the decisions from which are expected by the end of this year.

After that point, the ILEP will be replaced by a new TrustEd Ireland Authorised Providers: List of Eligible Programmes. QQI explains: “The new TrustEd Ireland list will identify those programmes that comply with immigration requirements to enable Immigration Service Delivery (ISD) in the Department of Justice, Home Affairs & Migration to determine applications for study visas and immigration permissions for study purposes.”

“All education providers intending to recruit non-EU/EEA/Swiss students that require study visas or immigration residence permissions for the purpose of study (where such residence exceeds 90 days) must ultimately secure authorisation from QQI to use the TrustEd Ireland mark.”

For additional background, please see:

• “Ireland to open applications for new quality assurance mark in September 2024“
• “Ireland’s ELT sector reports modest growth in student numbers but weeks are down amid ‘real and consequential’ challenges“
• “Irish higher education reports a fourth straight year of foreign enrolment growth“

The post TrustEd Ireland quality mark rollout continues with awards to first group of English-language schools appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

Representatives from more than 150 Canadian language programmes (English and French) responded to both the 2024 and 2025 editions of the survey, providing an analytical basis from which to compare trends in both years. The topline finding is that the number of students decreased by -13% and student weeks by -19% between 2024 and 2025.

Just over 81,600 students were enrolled in language programmes in 2025 (92% in English, 8% in French), collectively spending about 798,900 weeks in their studies.

The following chart from the report shows that the marked downward trend in student weeks began in 2023/2024. The language training sector is now roughly half the size it was in the year before the COVID-19 pandemic.

The value of the sector

Canada’s immigration policies have had a pronounced negative impact on international student numbers in Canadian institutions – and a much greater impact than the government anticipated. The result has been devastating for many institutions across levels and sub-sectors, but especially for language-training providers, which receive far fewer study permit allocations than universities do. In the foreword to the Languages Canada report, Gonzalo Peralta, the association’s executive director, notes:

“These policy decisions have significantly reduced enrolments, forcing programs to scale back operations and, in some cases, close entirely.

“While economic uncertainty and increased international competition contributed to the downturn, it is the policy environment that most decisively undermined the sector’s stability and growth. The consequences are felt across the country, with institutions struggling to maintain viability and communities losing the economic and cultural benefits these programs provide.”

What is at stake is not only the sustainability of the sector, but also millions of dollars. Languages Canada reports:

“Even amid this crisis, Languages Canada members contributed an estimated CDN$1.03 billion directly to the Canadian economy in 2025 – representing direct economic activity, much of it generated through export revenues – highlighting the sector’s enduring value.”

The estimated economic impact of the sector decreased by -1% in 2025 versus 2024.

Top 10 markets

Japan is the main sender of students and by far the largest contributor of student weeks. The top 10 markets for Canadian language programmes (with numerical values in the chart below) are:

• Japan
• Brazil
• South Korea
• Mexico
• Canada (Canadian students studying French or English in their own country)
• China
• Colombia
• Taiwan
• France
• Italy

All markets are down – some of them significantly – other than Canada, which is relatively stable. This fact alone highlights the damaging effect of immigration policies that of course do not affect Canadian students applying to their own country’s language programmes.

Destination comparison

The Canadian language training sector is not alone in facing difficult trading conditions. In terms of student weeks – a more indicative source of volume for language programmes than student numbers – the change between 2024 and 2025 was -8% in the US, -10% in the UK’s private sector, and -18% in Ireland.

In Australia, official data on student weeks for the English-language (ELICOS sector) has not yet been released, but:

• ELICOS’s share of total international enrolments nearly halved between 2023 and 2025 (from 16.6% to 8.8%);
• Student numbers fell from 97,200 in 2024 to 60,850 in 2025;
• Visa applications for ELICOS study dropped by -39% in 2025 versus 2024.

Similar to Canada, Australian government policies are the major contributor to the sector’s troubles. In Canada, the issue is the student cap that disproportionately affects language providers. In Australia, the main depressor on demand is the steadily rising visa application fee, which now stands at AUS$2,050 for English-language applicants. Applying for an Australian study visa is now roughly as expensive as a short English-language course of 10 weeks – and the application fee is non-refundable for students who are rejected for a visa.

Languages Canada vows to continue lobbying

Writing in the Languages Canada report, Mr Peralta says:

“While the findings present a stark and candid assessment, Languages Canada remains committed to working with its members and partners to advocate for the changes needed to stabilise and rebuild Canada’s English and French language education sector, support learners from Canada and around the world, and ensure that these essential programs can survive and recover.”

For additional background, please see:

• “US: ELT weeks fell by nearly 8% in 2025”
• “UK’s ELT sector reports declining enrolments through first quarter of 2026”
• “Ireland’s ELT sector reports modest growth in student numbers, but weeks are down amid ‘real and consequential challenges’”
• “Australia: Full-year data for 2025 reveals impact of AUD$2,000 study visa fee on ELICOS sector”
• “Canada’s language training sector reinvents pathway programme model in response to policy settings”

The post Canada’s language training sector in “state of crisis” after further enrolment declines in 2025 appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

This is the most serious sanction that can be levelled against a licensed sponsor. Revocation of the sponsor licence means that Bloomsbury, formerly the London School of Business and Management, immediately loses the ability to sponsor international students under the UK’s Student Route.

This means that it can no longer issue Confirmation of Acceptance for Studies (CAS). Any CAS already issued also now becomes invalid, and any pending visa applications based on a Bloomsbury CAS will be refused. The Institute will also be removed from the Register of Student Sponsors.

The revocation of the Bloomsbury Institute’s sponsor licence on 5 August 2026 follows the suspension of its licence on 9 June 2026, from which point it was forced to also suspend recruitment of international students.

The Institute’s licence was in the balance this year because Bloomsbury had not maintained compliance with the Basic Compliance Assessment (BCA) requirements. As the Home Office explains: “The Basic Compliance Assessment is an annual check that all sponsors must pass, measuring visa refusal rates, course enrolment and completion.”

Those BCA thresholds tightened this year, but Bloomsbury was assessed against the earlier benchmarks, which required that all sponsors maintain a visa refusal rate of less than 10%, an enrolment rate of at least 90%, and a course completion rate of at least 85%.

“Student sponsors must meet the standards required to retain their licence,” said the Home Office. “Failure to meet these standards represents a serious breach of its duties as an international student sponsor, and as a result, [Bloomsbury’s] licence was revoked.”

Effective 1 June 2026, the BCA thresholds were further strengthened such that visa refusal rates must be maintained below 5%; the course enrolment rate must be at least 95%; and the course completion rate must be at least 85%. Perhaps unnecessarily, the Home Office notes as well that, “The Bloomsbury Institute would also have failed to meet the new, stricter standards.”

A largely international student body

For 2024/25, the most recent available reporting year, HESA data indicates that the Bloomsbury Institute enrolled a total of 1,035 students. More than 800 of those, or nearly 80%, were international students, with the lion’s share (93%) coming from Pakistan.

The revocation of the sponsor license necessarily places the study programmes of those students, and even the future of the institution, in question. The Home Office says that its priority now is to “minimise disruption for international students already enrolled” at Bloomsbury.

To that end, the Institute “will be permitted to continue teaching its current sponsored students for a short period,” the term of which is not specified. Students who cannot complete their studies within that window will be supported to transfer to another institution.

Needless to say, those provisions are an important feature of the Home Office announcement. The headline is that a UK institution has had its sponsor licence revoked. But of course, behind that headline, are the many affected staff and students who now must deal with the uncertainty that accompanies this sanction against their institution.

For additional background, please see:

• “Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment“
• “UK universities bracing for a further decline in international enrolments“
• “England: Government ‘remains of the view’ that the International Student Levy should go ahead; implementation planned for August 2028“
• “UK: Sponsored study visa issuances down, rejection rates up, and more“

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Based on institutional responses in IIE’s , the estimate is for a 9.5% decline in overall foreign enrolment in the US in fall 2026. This could result in . In economic terms, that translates to up to US$3.4 billion in lost spending and 39,000 jobs affected.

“The projections underscore what we’ve long warned,” said Fanta Aw, Executive Director and CEO of NAFSA. “US policy and regulations affect where international students plan to invest their future—and their decisions carry significant short- and long-term consequences for US society and economy, All Americans lose when international students and scholars are driven to more welcoming countries.”

Where is this coming from?

The analysis points to three major factors behind the projected decline in enrolment for 2026/27: reduced or diverted demand; process and policy around student visas; and policy uncertainty.

There are a number of indicators of declining demand for study in the US this year, whether those students are simply deferring their study plans or choosing an alternate destination. First, recent findings from the highlight that the international pool of doctoral candidates shrunk by -21% for 2026/27, a trend that led to an overall decline in international PhD admissions of -17%. Meanwhile, says that international applications filed via its college admissions platform are down -9% for the coming academic year. And, as we reported recently, nearly two-thirds of respondents to IIE’s Spring Snapshot Survey are expecting enrolment declines for 2026/27.

Those trends are no doubt influenced by a series of underlying issues around student visa processing. An expanded ban on travel to the US affecting citizens from 39 countries, including Nigeria, has been in place since 1 January 2026. While there has not been an outright pause on visa processing this year, the State Department’s prioritisation of visa processing for FIFA World Cup ticket holders traveling to the US supplanted the historical norm of prioritising student applicants during the peak processing months over spring and summer. Making the situation even more challenging, there are widespread reports of significant processing delays and in India, China, and Europe.

Finally, both announced and anticipated rule changes are combining to create additional uncertainty for international students in the US this year. A new rule will come into effect on 15 September 2025 to replace the longstanding “Duration of Status” framework with a fixed Admit-Until-Date (AUD). The new AUD mechanism sets a maximum limit for which a student visa can be granted, and requires continuing students to apply for an extension with US immigration officials. This, says NAFSA, creates “significant planning uncertainty for prospective students, particularly those considering longer-degree programmes,” and an issue which is compounded by “the current administration’s continued warnings that it intends to reform the Optional Practical Training programme.”

The need for speed

“Forfeiting the US position as the top destination for global talent hurts students, hospitals, research laboratories, the economy – and carries the real risk that the next big invention will not happen on US soil,” adds Dr Aw. “We urge the administration and Congress to take swift action to ensure international student contributions continue to benefit American ingenuity, economic prosperity, and national security.”

In order to ease the projected decline for 2026/27, NAFSA is urging the US administration to take the following steps.

• Prioritise processing for all F and M visa applicants as well as for those pursuing a J visa for exchange in the US;
• Exempt students and exchange visitors from the current travel ban “while maintaining background checks and vetting required for visa issuance”; and
• Preserve Optional Practical Training for foreign graduates in the US.

For additional background, please see:

• “Decline in Indian demand a major factor in softer outlook for foreign enrolment in US higher education in 2026/27“
• “Updated: US Department of Homeland Security publishes rule to end Duration of Status for international students“
• “US regulatory agenda for 2026 aims to end ‘duration of status and introduce Optional Practical Training and H-1B reforms“
• “US extends travel ban, Nigeria now included on ‘restricted’ list“

The post Visa delays and policy uncertainty projected to reduce foreign enrolment in the US by more than 100,000 students this fall appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

The hefty fee would apply to post-study Optional Practical Training (OPT) placements. Post-study OPT is the work stream that allows students who complete a minimum four-year bachelor’s degree to gain one to three years of work experience related to their field of study, and it often serves as a bridge from F-1 student status to at least three years in a formal position with a US employer on an H-1B visa. Three-year OPT is reserved for students with STEM degrees.

More than 294,000 students participated in OPT in 2024/25 – representing about one in four international students in the US. This was a 21% increase over the previous year.

Any move to limit access to OPT will upend foreign students’ estimation of the return on investment for study in the US. A recent Chronicle of Higher Education survey found that 8 in 10 international students would not choose to study in the US if they could not access OPT.

Nothing is certain yet

A Department of Homeland Security (DHS) spokesperson confirmed that the fee is under discussion, but it stressed in a statement to the paper that “no policy should be considered final until it is formally announced.” It is not clear yet who would have to pay the $100,000 OPT fee – students, universities, or employers.

OPT under fire

For decades, international students were permitted to stay in the US for as long as their study journey required, including three years of OPT participation, under a rule called Duration of Status, or D/S.

But a 2025 administration proposal to put fixed limits on international students’ legal status in the US will become a rule in September 2026. International students will have to leave after four years unless they submit, and are approved for, an extension by immigration officials.

This makes a potential $100,000 OPT fee even more off-putting to international students. Not only will they need to submit a request to US Citizenship and Immigration Services (USCIS) to stay in the US for longer than their length of their degree – with no guarantee they will be approved – but the $100,000 fee would make it even less likely that they would (1) be hired (if the fee were levied on employers) or (2) afford to be hired (if students themselves had to pay the fee).

If at first you don’t succeed …

It is quite possible that the government views a steep OPT price tag as a satisfactory equivalent to its September 2025 proclamation requiring employers to pay a $100,000 fee to sponsor a foreign worker for an H-1B visa. That ruling was later blocked in court. The administration submitted an appeal to reverse the decision, but a federal court rejected the appeal on 24 July 2026.

If the administration were to push through the $100,000 fee for OPT submissions, it could achieve the same goal as the as-yet unsuccessful H-1B fee of blocking a huge proportion of international graduates and skilled foreign workers from employment in the US.

Brain drain from the US is already happening

The potential for brain drain is real. The WSJ notes: “Advocates contend that without OPT, most international students would be forced to leave the country immediately after graduation, pushing them to take the skills they gained at American universities to foreign markets.”

Destinations such as Germany, France – and the US’s great-power rivals China and Russia – are already benefitting from lower student demand for the US. All these countries – and several more alternative destinations – are building their foreign enrolment at the same time as new international student commencements in the US (as well as in Australia, Canada, and the UK) decline.

The impact on universities and employers

International students’ contributions are vital to STEM-based sectors and to US innovation in general. For example, a 2025 Silicon Valley Index report found that 66% of technology workers in the region are foreign born.

The potential impact on Indian and Chinese enrolments

If enough Indian and Chinese students decide to stay away from the US, it could be a devastating revenue hit for many US colleges. More than half (53%) of all international students in academic programmes or OPT in the US are Indian or Chinese.

Doctoral-degree-granting institutions would be especially affected. Consider:

• Eight in 10 Indian students studying in the US in 2025 – and nine in 10 Chinese students – are enrolled at a doctoral college.
• Of 57,800 PhDs granted to all students in the US in 2023, 19,400 (34%) were awarded to F-1 international students, nearly half of whom (44%) were Chinese or Indian.
• Chinese and Indian students received nearly one-sixth (15%) of all PhDs awarded by US institutions in 2023.

It isn’t too dramatic to say that R&D innovation in the US would be significantly affected by a major fall-off in Indian and Chinese demand.

The Indian and Chinese flow of OPT students to US employers would also be severely impacted:

• Of all Indian students in the US in 2025, 40% were in OPT. This represents a near doubling of the proportion the previous year.
• Of all Chinese students in the US in 2025, 23% were in OPT.

Change is coming

Whether or not a $100,000 OPT fee comes into being, what is certain is that the Trump administration is currently considering new rules for OPT. There are few details at present, but new OPT rules are slated for introduction in February 2027. The government has indicated only that it will “amend existing regulations to address fraud and national security concerns, protect US workers from being displaced by foreign nationals, and enhance the Student and Exchange Visitor Program’s capacity to oversee the program.”

Lawsuits highly likely

Multiple lawsuits arose to fight the H-1B fee, and the fee has been declared unlawful. As of this writing, US employers do not have to pay the fee to hire international students or foreign skilled workers.

Litigation is already in process to contest the fixed admission rule set to come into force on 15 September 2026.

As reported by Forbes, “legal consultations have left experts questioning the administration’s lawful authority to impose a $100,000 OPT fee.”

For additional background, please see:

• “US regulatory agenda for 2026 aims to end ‘duration of status’ and introduce Optional Practical Training and H-1B reforms”

The post Report: US considering a $100,000 fee for Optional Practical Training appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

Meanwhile, the opposition Coalition, and, perhaps even more strikingly, the surging One Nation Party, continue to contend for public support, in part on a strong anti-migration message. The most recent opinion polling sees One Nation edging the official Liberal-National Coalition opposition for second place, and within striking distance of the governing Labor Party under Prime Minister Anthony Albanese.

All of which means it was noteworthy this week when the Minister for Immigration and Citizenship, Tony Burke, at The National Press Club. The Minister was widely expected to use the speech to “unveil far-reaching changes to Australia’s migration settings,” but a spokesperson for Minister Burke confirmed that “it became clear that some elements of the speech would not be finalised” in time for the Press Club appearance.

The move has led to considerable speculation over the direction of migration policy. Writing in , the University of Canberra’s Michelle Grattan said, “What this week’s toing and froing also signals is that the government knows making more drastic changes to immigration to bring it under control is now a strong political imperative.”

There is some irony in those political headwinds in that migration levels in Australia have actually been declining in recent years – the key measure for which is the Net Overseas Migration figure (NOM).

The NOM is the Australian Bureau of Statistics’ official indicator of the migration contribution to population change. The methodology behind it is somewhat complex and laggy, but in short: the NOM calculates the difference between the number of people arriving to live in Australia and the number leaving to live elsewhere, regardless of citizenship or visa type (and including Australian citizens and permanent residents).

The most recent NOM calculation is for the year ending 30 June 2025, when it was reckoned at 306,000 people. That is down significantly from 429,000 the year before (-34%), and even more dramatically from the post-pandemic peak of 538,000 people in 2022/23.

The 2025 NOM nets out 568,000 arrivals for that year against 263,000 departures, with international students as the largest single arrivals group (157,000).

In its budget planning documents, the Albanese government estimates that the NOM will edge down to 295,000 in 2025/26 before arriving at a longer-term target of 225,000 by 2027/28. That 225,000 figure can be debated in many different directions but it seems clear that it will become something of a political fulcrum around which the debate about migration will revolve in the months and years ahead.

Watch for the signs

With that comment about the “political imperative” to reduce net migration numbers ringing in our ears, let’s reflect on some of the recent moves to constrain migration, and inbound student movement in particular. These are noteworthy in part because they are all a function of tightening processes and settings within government – as opposed to legislation or other formal regulatory intervention – and have generally been introduced without consultation or even any significant lead time.

For example, on 1 July 2026, the following visa application fee increases were enacted with immediate effect and without prior notice.

• Student visa application fee for higher education and vocational (VET) studies (subclass 500): AU$2,000 to AU$2,500, unless students are from ASEAN countries (AU$2,050)
• Student visa fee for English-language studies (ELICOS): AU$2,000 to AU$2,050
• Temporary Graduate Visa 485 (for post-study work): AU$4,600 to AU$5,750
• Partner visa: AU$9,365 to AU$11,710

On 1 March 2026, also for immediate implementation and without warning, the application fee for the Temporary Graduate Visa (subclass 485) doubled to AU$4,600 from AU$2,300. (Meaning that the 1 July increase for subclass 485 was the second significant increase for this visa category within four months.)

Visa approval rates have also been trending down through 2026. In February 2026 alone, one out of every three students applying to an Australian university was rejected and that monthly refusal average (32.5%) was the most significant in 21 years of tracking. The approval rate for student visa applications dipped again in March, to 59%, and the year-to-date approvals through May 2026 ran at just 72% overall (which was again a 20-year low for that January to May period).

Most recently, the Department of Home Affairs has for most eligible countries for the Work and Holiday (subclass 462) programme. The programme includes a hard cap on the number of first Work and Holiday visas that can be granted to applicants from specific countries, and it appears that that limit has already been reached for most within a month of the application window having opened for this year on 2 July.

This could be read as another restriction on inbound mobility. But it should be said that closing that application window is not unusual, and that the immigration system normally “pauses” Work and Holiday applications when those cap limits are reached.

Further, the cap limits are specific to the Work and Holiday (subclass 462). There is a related subclass 417 () which, while reporting higher-than-normal application volumes this year, remains open to eligible applicants. Taken together, there were roughly 225,900 Working Holiday Makers in Australia as of 31 December 2025 (counting visitors on both 417 and 462 visas).

For additional background, please see:

• “Australia: As visa applications from foreign students fall, the government has set the national target for new international students in 2027“
• “Surprise hike in international student visa application fees ‘a direct hit to Australia’s competitiveness’“
• “Universities urged to focus on ‘factors they can control’ as policy settings depress international student enrolments in the Big Four“
• “Australia: Multiple data indicators signal further declines ahead for international student numbers“

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