Form I-9 for CPT Students: Documents and Employer Steps

Hiring an international student for a paid internship often raises a specific question: What documents does an F-1 student on Curricular Practical Training need for Form I-9?

CPT does not ordinarily involve an Employment Authorization Document, or EAD. Instead, an F-1 student may establish identity and employment authorization with a combination of documents that includes a Form I-20 endorsed for CPT.

For employers, the critical details are the authorized employer, employment dates, and whether the authorization covers part-time or full-time training. Here is a practical workflow for getting those details right.

What is CPT, and how is it different from OPT?

Curricular Practical Training is employment-related training that is an integral part of an F-1 student's established curriculum. It can include internships, cooperative education, or other qualifying practical training.

A designated school official, commonly called a DSO, authorizes CPT through the Student and Exchange Visitor Information System, or SEVIS, and provides the student with an endorsed Form I-20.

Unlike Optional Practical Training, CPT does not require the student to obtain an EAD from USCIS. The student must receive CPT authorization before beginning the training, and employment cannot begin before the authorized start date.

This distinction matters during onboarding. An HR checklist that requires an EAD from every international student can delay a properly authorized CPT hire and create document-request problems. For the separate OPT process, see our Form I-9 checklist for OPT and STEM OPT employees.

Which documents can establish CPT employment authorization?

For an F-1 student authorized for CPT, the following combination can serve as List A documentation:

• An unexpired foreign passport.
• Form I-94 or Form I-94A indicating F-1 nonimmigrant status.
• Form I-20 with the DSO's CPT employment endorsement.

These documents work together. The passport alone does not establish CPT employment authorization, and a Form I-20 showing school enrollment without the relevant CPT endorsement is not enough.

The authorization must cover the employment being offered. Review the employer information, authorized dates, and part-time or full-time designation on the Form I-20.

Do not require this combination from every student

Employees retain the right to choose which acceptable Form I-9 documents to present. Explain the Lists of Acceptable Documents without insisting on a passport, EAD, or other specific document because of a person's citizenship or national origin.

If an employee presents the CPT document combination, however, HR must review the complete combination—not treat one component as sufficient by itself. Accept documents that reasonably appear genuine, relate to the employee, and satisfy the applicable requirements.

A five-step onboarding workflow for CPT hires

1. Confirm the proposed job matches the authorization

Coordinate with the student before scheduling the first workday. Check that the CPT endorsement identifies your employer and covers the planned training period and work arrangement.

If the employer name differs because the offer uses a brand name while the authorization uses a legal entity name, resolve the discrepancy rather than assuming it is harmless. The student can work with the DSO to clarify or correct the authorization.

HR should not decide whether a job qualifies academically for CPT. That determination belongs with the school and its authorization process.

2. Keep the start date within the authorized period

A completed Form I-9 does not create employment authorization. Neither does an offer letter, a pending school request, or an assurance that an updated Form I-20 is coming.

For example, suppose an internship offer lists May 20 as the first day, but the CPT endorsement authorizes employment beginning June 1. The student cannot begin the CPT employment on May 20. HR should adjust the schedule or have the student resolve the authorization before any earlier start.

Treat required job training and onboarding activities that constitute employment as part of this scheduling review.

3. Complete Form I-9 on the normal schedule

CPT does not provide an exception to ordinary Form I-9 deadlines:

• The employee completes Section 1 no later than the first day of employment for pay.
• The employer completes Section 2 within three business days after that first day.
• For employment lasting fewer than three business days, Section 2 must be completed no later than the first day.

In Section 1, an employee relying on CPT generally selects the time-limited employment authorization option and enters the applicable authorization end date. An I-94 notation of “D/S,” meaning duration of status, does not make CPT employment authorization indefinite.

4. Record the complete document combination

When the employee presents the CPT List A combination, record the relevant passport, I-94, and endorsed Form I-20 information using current USCIS instructions.

Electronic systems should support a multi-document List A combination. Avoid forcing the record into a single-document category or entering an EAD document type when no EAD was presented.

Also follow the applicable document examination procedure. Receiving scans by email alone does not satisfy physical examination requirements or the DHS-authorized alternative procedure.

5. Schedule reverification before CPT expires

Use the CPT authorization end date to create a reverification reminder. Do not use the passport expiration date or the student's general academic program end date as a substitute.

Before the existing employment authorization expires, the employee must present acceptable evidence of continued authorization for employment to continue. Complete Supplement B as required.

At reverification, allow the employee to choose an acceptable List A or List C document. Do not automatically demand another passport or assume the next authorization must also be CPT.

What if the internship changes or gets extended?

A manager's approval to extend an internship does not extend CPT authorization.

Route proposed changes in dates, employer, hours, or work location to HR before implementation so the student can confirm with the DSO whether updated authorization is needed. This is especially important when a part-time position becomes full-time or a student moves to a different employing entity.

An anticipated extension is not evidence of continued work authorization. If the current authorization expires without acceptable evidence supporting continued employment, the employee cannot keep working on the strength of the pending request alone.

Build CPT checks into your hiring process

For employers hiring students across multiple departments, assign clear ownership:

• Recruiting: Communicate the proposed employer, dates, and schedule accurately.
• HR: Review Form I-9 documentation and track authorization deadlines.
• Managers: Obtain HR review before changing the assignment or extending work.
• Payroll: Coordinate approved start and stop dates with HR.

A centralized process, supported by Clear I-9, can help keep document review and follow-up from becoming disconnected tasks.

Confirm current requirements in USCIS guidance on students and employment and the current Form I-9 instructions. This article provides practical guidance, not legal advice; involve qualified immigration counsel when authorization is unclear.

Need a more consistent process for student hires and other time-limited authorizations? Contact Trak Services to discuss your I-9 workflow.