My prediction for the timeframe for DHS's new rules implementation (Next March or Fall). Please share your thoughts

1. Proposal just published (Aug 28, 2025) → only at the draft stage.
   • Comments closed Sept 29, 2025.
   • No current final rule yet.
2. Past DHS rules for F-1 students:➝: Normal cases cluster around ~400 days from proposal → final.
   • H-1B modernization (with F-1 cap-gap fix): ~422 days NPRM → Final.
   • USCIS fee rule (affects OPT fees): ~392 days NPRM → Final.
   • STEM-OPT 2016 (special fast case due to court order): only ~144 days.
3. Effective date delays (after final):
   • By law (APA), usually ≥30 days. → Once the government publishes the final version of a rule, it usually can’t start for at least 30 days. This is a built-in waiting period.
   • If “major” under CRA, ≥60 days. → If the rule is considered especially important or “major,” the waiting period is at least 60 days before it begins.
   • Recent rules (fee rule, H-1B) had 30–60 days delay. → For example, the recent USCIS fee rule took about 60 days before starting, and the H-1B modernization rule took about 30 days.
4. This F-1 proposal is big + controversial (ending D/S, new extension system).
   • Likely many comments.
   • Likely full OIRA review (up to 90 days).
   • So, expect timing on the slower side.

So, I'm assuming the rule could be implemented at the earliest next year, February/March, or by next fall at the latest.

Ps. I have also shared this on my other accounts, so I'm sharing it once more with you all!