No. USCIS says "You may not begin your pre- or post-completion OPT until after we approve your Form I-765." Study in the States adds that you may begin OPT only after USCIS approves the form, you receive your EAD, and the start date on the EAD arrives. A pending application, or an approval notice without the card in hand, is not enough.
The three conditions
Study in the States puts it this way: "You may begin OPT only after USCIS approves your Form I-765, you receive your EAD and the start date on the EAD arrives." The federal regulation says the same thing in different words: a student "may not begin optional practical training until the date indicated on his or her employment authorization document" (8 CFR 214.2(f)(10)(ii)(A)). The USCIS Policy Manual repeats it: "The student may not begin OPT until the date indicated on the student's employment authorization document."
- USCIS approves your Form I-765.
- You have the card, the Employment Authorization Document (EAD).
- The start date printed on the card has arrived.
Pre-completion and post-completion OPT
The same approval rule covers both kinds. They differ in how much you may work:
- Pre-completion OPT (during your studies): USCIS says "you may work (20 hours or less per week) while school is in session."
- Post-completion OPT (after your program): USCIS says "you must work part time (at least 20 hours per week) or full time."
For post-completion OPT, the SEVIS guide says the start date "must be on or after the Program End Date." The filing windows are on the same official pages. Study in the States says you may file "up to 90 days before you complete your degree," must file within 60 days after completing your degree, and "must file your post-completion OPT application within 30 days after your DSO's OPT recommendation in SEVIS." DSO means designated school official. For how long approval takes, see the I-765 processing times page and USCIS's own tool at egov.uscis.gov/processing-times. We do not state a timeframe here, because USCIS's tool changes.
Traveling while the application is pending
Study in the States says: "If you have a pending practical training application, it is not recommended that you leave the United States." It explains that USCIS may send a request for evidence while you are away, and that USCIS sends those requests only to your U.S. address. ICE's travel page says traveling during this time "should be undertaken with caution" and tells you to keep a correct U.S. address on file with your DSO and on the application.
After approval, both pages say you are "expected to have your EAD in hand to re-enter the United States." ICE lists the other travel documents as your Form I-20, passport, visa and any employment letter. Ask your DSO before you book a trip.
A rule change that is on hold
DHS published a final rule on July 17, 2026 titled "Establishing a Fixed Time Period of Admission and an Extension of Stay Procedure." USCIS has an alert on its Form I-539 and Form I-765 pages, dated Sept. 14, 2026, which the pages showed as reviewed on 10/07/2026. It says the U.S. District Court for the District of Massachusetts issued an order postponing the rule's effective date, that "DHS is preliminarily enjoined from taking any further action to implement the final rule," and that "Until such time, USCIS will proceed under the previous regulatory provisions." That is all the alert says, and it can change. Your designated school official (DSO) is the person to ask which rules apply to you.
Common questions
Can I start on the day my program ends?
Only if you have the EAD and the start date on it has arrived. The SEVIS guide says the start date must be on or after the program end date, so the card controls.
Does the approval notice let me start?
The official wording is that you may begin after USCIS approves the form, you receive the EAD and the start date arrives. All three are listed together, so an approval notice by itself does not meet them.
Can I work for my employer as a volunteer until the card arrives?
The pages we read do not carve out an exception. The Policy Manual says only that a student may work as a volunteer or unpaid intern as long as this does not violate labor laws, and the OPT rule still requires the EAD start date. Ask your DSO.
Is there any case where a pending application lets me keep working?
USCIS describes one: if you file your STEM OPT extension application on time and your OPT period expires while it is pending, USCIS says it will automatically extend your employment authorization for 180 days. USCIS ties this to a STEM OPT extension filed on time. See our guide to the 180-day rule. That is a different situation from starting your first OPT period.
Official sources
- Study in the States: Applying for Practical Training
- USCIS: Optional Practical Training (OPT) for F-1 Students
- USCIS: Form I-539 (court order alert)
- USCIS Policy Manual, Volume 2, Part F, Chapter 5
- Study in the States: Traveling as an F or M Student
- ICE SEVP: Travel
- Study in the States: F-1 Optional Practical Training (SEVIS Help Hub)
GreenLight is not affiliated with USCIS or the U.S. government. This article is for informational purposes only and does not constitute legal advice.