For decades, F-1 students, J-1 exchange visitors, and I visa holders have carried a kind of built-in flexibility that most other visa categories never had. Instead of a fixed expiration date, their Form I-94 simply read “D/S,” short for Duration of Status. As long as they stayed enrolled or engaged in their program, that notation did the work of tracking their status for them.

Effective September 15, 2026, that changes. A new rule eliminates the D/S notation for F-1 students, J-1 exchange visitors, and I visa foreign media representatives. Going forward, these individuals will receive a specific expiration date on their I-94, the same way most other visa holders already do.

For HR and Legal Ops teams supporting employees who came through OPT, STEM OPT, or a J-1 exchange visitor program, this is not a filing footnote. It is a shift in how closely your team may need to track status dates that used to take care of themselves.

What Is Actually Changing

Here is the mechanical shift, in plain terms:

  • The Department of Homeland Security (DHS) will stop issuing the open-ended D/S notation on I-94 documents for F-1, J-1, and I visa classifications.
  • Instead, these individuals will receive an admit-until date (AUD), a specific expiration date, similar to what H-1B or L-1 employees already receive.
  • The I-94 document issued last in time is what controls a person’s lawful status in the United States. That has always been true. What changes is that F, J, and I visa holders will now have a real date on that document instead of an open-ended “D/S.”

Students and exchange visitors will still be tracked through the Student and Exchange Visitor Information System (SEVIS), which DHS already uses to monitor enrollment and program status. For F-1 students, the school’s Designated School Official (DSO) issues a new Form I-20 when program details change. For J-1 exchange visitors, the Program Administrator issues an updated DS-2019. That part of the system is not going away.

What is going away is the administrative buffer that let minor program changes, like an extra semester or a shift in research focus, get absorbed quietly through SEVIS without creating a status question. Under the new rule, that buffer narrows.

Why DHS Made This Change

The stated purpose is straightforward: more consistent government oversight, vetting, and monitoring across visa categories. As a practical matter, it also means there are now more ways for a person to fall out of status without realizing it.

I-94 errors are common even under the current system. A student can receive a new I-20 for a legitimate program change and never think to check whether their I-94 reflects it, because historically, it did not need to. Under the new fixed-date system, a missed update is no longer a paperwork inconsistency. It is a status problem.

This is worth explaining to affected employees directly, in calm and practical terms. The consequence of an extended lapse in status, more than 180 days for some triggers or a year for others, followed by departure from the U.S., can be a bar on returning for a period of years. That is a significant outcome for what often starts as a missed form.

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The Transition Rules HR Should Know Now

The rule does not flip a switch on every current F, J, and I visa holder at once. The transition works like this:

  • Anyone here now, who does not travel internationally: Their D/S status continues to be measured against the end date of their program as listed on their I-20 or DS-2019, up to a maximum of September 15, 2030 (four years from the effective date). No one can hold D/S status past that date.
  • Anyone who travels internationally and re-enters after September 15, 2026: They will receive an I-94 with a specific expiration date instead of D/S, regardless of how long they have been in the U.S. under the old system.
  • Grace period change: For individuals who leave and re-enter after September 15, 2026, the grace period at the end of their authorized stay is shortened to 30 days.
  • Extensions beyond the stated program end date: Individuals needing more time will need to file Form I-539 to extend their status with U.S. Citizenship and Immigration Services (USCIS), or depart the U.S. and re-enter with an updated I-20 or DS-2019.

In short: employees who stay put and do not travel may not notice much of a change right away. Employees who travel internationally after September 15 will feel the shift immediately, in the form of a hard expiration date where there used to be none.

A Practical Checklist for HR and Legal Ops

  1. Identify who this affects. Pull a list of current employees on F-1 (including OPT and STEM OPT) and J-1 status, along with anyone in an I visa classification.
  2. Flag upcoming international travel. Any employee in one of these categories who is planning to leave and re-enter the U.S. after September 15, 2026 will return with a fixed I-94 expiration date. Build this into travel approval conversations now.
  3. Confirm SEVIS documentation is current. Encourage employees to verify that their most recent I-20 or DS-2019 accurately reflects their current program details before any international travel.
  4. Watch the 2030 ceiling. Employees who remain in the U.S. without travel are still bound by the September 15, 2030 maximum for continued D/S coverage. This is a long runway, but it belongs on a long-term tracking calendar, not a mental note.
  5. Plan for I-539 conversations early. If an employee’s program will run past their eventual fixed expiration date, an extension filing may be necessary. Waiting until close to the date narrows the options.
  6. Update your own internal tracking. If your team has relied on D/S as a reason not to track certain visa categories closely, this is the moment to close that gap.

Where Direct Counsel Fits In

None of this requires a dramatic response. It does require attention, especially for employees with upcoming travel plans or programs that are close to their natural end date. When a specific employee’s situation raises a question, whether it is how a new I-94 date interacts with an existing I-20, or whether an I-539 filing makes sense before a trip abroad, that is exactly the kind of question Nadalin OnCall+ was built for. It gives your team direct access to experienced immigration counsel when a matter falls outside the standard process and a general FAQ will not cut it.

Key Takeaways

  • D/S ends September 15, 2026 for F-1, J-1, and I visa holders. They will receive a fixed I-94 expiration date going forward.
  • SEVIS tracking through the I-20 and DS-2019 continues. What changes is how tightly the I-94 date now needs to match it.
  • Employees who do not travel keep D/S status through their program end date, capped at September 15, 2030.
  • Employees who travel and re-enter after September 15, 2026 receive a fixed expiration date immediately, along with a shortened 30-day grace period.
  • Extensions beyond the stated program end date may require an I-539 filing or departure and re-entry with updated documentation.

Frequently Asked Questions

Does this rule affect employees who are not planning to travel internationally? Not immediately. Employees who remain in the U.S. continue under D/S through their program end date, up to the September 15, 2030 maximum. The practical impact is greatest for employees who travel and re-enter after the effective date.

What happens if an employee’s I-94 does not match their most recent I-20 or DS-2019? The I-94 issued last in time controls lawful status. A mismatch between SEVIS records and the I-94 can create a status question, which is why confirming current documentation before travel matters.

Is the 30-day grace period change automatic for everyone? No. The shortened 30-day grace period applies to individuals who leave the U.S. and re-enter after September 15, 2026. It does not apply retroactively to people who stay in the country without traveling.

What should HR do if an employee’s program is likely to run past their new fixed I-94 date? This is a case where planning ahead matters. Depending on the facts, an I-539 extension filing or a departure and re-entry with updated I-20 or DS-2019 documentation may be the path forward. A conversation with counsel before the date approaches gives your team more options.

Can AI tools help HR track these dates across a large population of F-1 and J-1 employees? AI can help organize employee data, flag upcoming expiration dates, and prepare questions ahead of a conversation with counsel. It is a useful layer for staying organized. Interpreting how a specific employee’s situation should be handled, and deciding what to file and when, still calls for experienced immigration judgment.

Ready to get ahead of this change? Contact Nadalin Law to talk through how the D/S elimination affects your F-1, J-1, and I visa employees, or ask about Nadalin OnCall+ for direct access to counsel on specific cases.