Does unpaid, volunteer or part-time work count as OPT employment?

Post-completion OPT vs. STEM OPT at a glance

Each row is explained below, with links to the sources.

Does volunteer or unpaid work count on post-completion OPT?

It can. The USCIS Policy Manual says: "A student may work as a volunteer or unpaid intern, as long as this practice does not violate any labor laws, and the employment is related to the program of study. The student must work at least 20 hours per week." (USCIS Policy Manual, Vol. 2, Pt. F, Ch. 5)

That sentence cites SEVP's 2010 OPT guidance, which lists "Unpaid employment" among the types of OPT work and adds an evidence rule: "A student must be able to provide evidence acquired from the student's employer to verify that the student worked at least 20 hours per week during the period of employment." (§7.2.1, SEVP Policy Guidance 1004-03) ICE says this guidance "remains in effect," except where its 17-month STEM content conflicts with the 2016 STEM rule (ICE, Practical Training).

So an unpaid or volunteer role has three tests to meet:

1. It doesn't violate labor laws.
2. It relates to your program of study.
3. It's at least 20 hours a week.

The labor-law condition

Neither USCIS nor SEVP says which labor laws it means. For federal wage law, the Department of Labor's Fact Sheet #71 covers interns at "for-profit" employers:

• "The FLSA requires 'for-profit' employers to pay employees for their work." Interns may not be "employees," and courts decide that with the "primary beneficiary test," a seven-factor test in which "no single factor is determinative."
• Its footnote treats nonprofits differently. The Wage and Hour Division recognizes an exception for people who volunteer "freely and without anticipation of compensation, for religious, charitable, civic, or humanitarian purposes to non-profit organizations." It adds: "Unpaid internships for public sector and non-profit charitable organizations, where the intern volunteers without expectation of compensation, are generally permissible."

The fact sheet covers the federal Fair Labor Standards Act only, and it says it doesn't have "the force and effect of law." Whether a specific unpaid role meets labor laws is a question for the organization and, if needed, an employment attorney. Ask your DSO before you report the role as OPT employment.

Volunteering that isn't related to your degree

SEVP is direct about this (Study in the States, Reporting Volunteer Positions During OPT Employment):

• "A volunteer position that is not directly related to an F-1 student's course of study does not qualify as optional practical training (OPT) and must not be listed as OPT employment" in SEVIS.
• "If you report a non-qualifying volunteer position as OPT employment, you are violating your reporting requirements and are subject to removal from the United States."

The post is from July 5, 2018, and the page carries a note that its content may be outdated. The current USCIS Policy Manual still cites it (Ch. 5, footnote 44). The post doesn't say unrelated volunteering is forbidden. It says such a role doesn't count as OPT and must not be reported as OPT employment.

The 20-hour minimum and variable schedules

Post-completion OPT

• USCIS: "If you are authorized for post-completion OPT, you must work part time (at least 20 hours per week) or full time." (USCIS, OPT for F-1 Students)
• The SEVIS Help Hub: post-completion OPT "must be at least 20 hours per week or full-time" (SEVIS Help Hub, F-1 OPT).
• SEVP's 2019 guidance on the degree link adds, in a footnote: "For the purpose of this policy, full time is considered to be 20 hours or more per week." (SEVP Policy Guidance, Determining a Direct Relationship, Sept. 27, 2019)

Variable schedules. "A student must work at least 20 hours per week in a qualifying position to be considered employed. If a student has a variable schedule, within a month, it should average out to at least 20 hours per week." (§7.1.5, SEVP Policy Guidance 1004-03)

Fictional example. A student works 15, 25, 22 and 18 hours in four weeks. That's 80 hours, or an average of 20 hours a week over those four weeks. The guidance doesn't explain how to work out the average for a calendar month, so keep timesheets or pay records that show your weekly hours, and ask your DSO if your hours often dip below 20.

STEM OPT

• Each employer. A STEM OPT student must "be employed for no less than 20 hours per week by each qualifying STEM OPT employer" (USCIS Policy Manual, Ch. 5).
• Leave. The regulation: "A student may not engage in practical training for less than 20 hours per week, excluding time off taken consistent with leave-related policies applicable to the employer's similarly situated U.S. workers in the area of employment." (8 CFR 214.2(f)(10)(ii)(C)(8))
• A drop in hours is a material change. SEVP lists "Any significant decrease in hours per week that a student engages in a STEM training opportunity" as a material change to report to your DSO (Study in the States, STEM OPT reporting requirements). The Form I-983 guide covers modified training plans.
• Part-time work doesn't add time. "STEM OPT is not extended by periods of part-time employment or unemployment." (USCIS Policy Manual, Ch. 5)

Unpaid internships and volunteering on STEM OPT

Not allowed as STEM OPT training. The sources agree:

• SEVP: "volunteer positions do not meet the conditions of a science, technology, engineering and mathematics (STEM) OPT extension. If you are completing a 24-month STEM OPT extension, you must receive compensation for your training opportunity." (Reporting Volunteer Positions During OPT Employment)
• USCIS: the employer "may not be the student's 'employer' in name only, nor may the student work for the employer on a 'volunteer' basis" (USCIS, STEM OPT).
• The regulation: duties, hours and compensation "must be commensurate" with those of the employer's similarly situated U.S. workers, and "The student must disclose his or her compensation, including any adjustments, as agreed to with the employer, on the Form I-983" (8 CFR 214.2(f)(10)(ii)(C)(8)).
• The employer must be enrolled in E-Verify and have an EIN (8 CFR 214.2(f)(10)(ii)(C)(5)).

Start-ups and alternative compensation, such as stock options, are covered in the STEM section of our self-employment post.

Several part-time jobs: can you add up the hours?

Post-completion OPT: more than one employer

You may have more than one employer. SEVP's 2010 guidance says: "A student may work for more than one employer, but all employment must be related to the student's degree program and, for pre-completion OPT, can not exceed the allowed per week cumulative hours." (§7.2.1, SEVP Policy Guidance 1004-03)

The word "cumulative" in that sentence sets a ceiling for pre-completion OPT. The guidance doesn't say how hours from several jobs are treated on post-completion OPT. The written description a DSO collects for each employer includes "Whether the employment is full-time or the average number of hours worked per week" (SEVIS Help Hub, Add, Edit, Delete OPT Employer).

STEM OPT: 20 hours with each employer

No. The 20 hours apply to "each qualifying STEM OPT employer" (USCIS Policy Manual, Ch. 5). Two 12-hour jobs don't meet the rule, even though they add up to 24.

Fictional example. Ken is on post-completion OPT with two part-time jobs, both related to his degree: 12 hours a week at a design studio and 12 hours a week at a museum. Each job is under 20 hours. Together they make 24. No official source we found says whether 24 combined hours meet the minimum, so Ken asks his DSO how the two jobs will appear in SEVIS before he relies on them. If Ken were on STEM OPT, neither job would meet the 20-hours-per-employer rule.

Campus jobs after graduation

Many students hold a campus job until their program ends. The regulation says what happens next:

• "Otherwise, an F-1 student may not engage in on-campus employment after completing a course of study, except employment for practical training as authorized under paragraph (f)(10) of this section." The other exception is a student with a Form I-20 for a new program "who intends to enroll for the next regular academic year, term, or session at the institution that issued the Form I-20" (8 CFR 214.2(f)(9)(i)).
• ICE: "May an F-1 student work on campus during the 60-day grace period after the program end date? No." It adds that a student "may consider applying for post-completion OPT to continue working after graduation" (ICE, SEVIS employment FAQ).

So after your program ends, unless you continue to a new program at the same school, the regulation allows work at your school only as practical training. The OPT tests in this post then apply to it: it can't start before your EAD start date, it must relate to your degree, and it must meet the 20-hour minimum. If your campus job could run past your program end date, ask your DSO before your last day of classes. The waiting period before your EAD arrives is covered in Can you work while your OPT is pending?

Does the work have to relate to your degree?

Yes, for every kind of OPT work: paid, unpaid, volunteer, part time or full time.

• The rule. OPT is employment "directly related to the student's major area of study" (8 CFR 214.2(f)(10)(ii)(A)). USCIS: "All OPT must be directly related to your major area of study." (USCIS, OPT for F-1 Students)
• You explain it. SEVP's 2019 guidance says "students are responsible for providing a description of how their job relates to their major area of study, which the DSO must review and retain." (SEVP Policy Guidance, Sept. 27, 2019)
• Your DSO decides. The same guidance says a DSO "must make a determination of whether there is a direct relationship between the job and the major area of study," on "a case-by-case basis." The question is whether there is "a logical connection" between the duties and your major.
• Titles and workplaces aren't enough. The guidance gives two examples. A music graduate who lists a restaurant "could be employed as a musical entertainer." And a DSO "should not assume a direct relationship just because a student with an accounting degree reports working at an accounting firm."
• On STEM OPT, Form I-983 "must include how the training opportunity has a direct relationship to the student's qualifying STEM degree" (Study in the States, Determining STEM OPT Extension Eligibility).

Hours and the degree link are separate tests. A related role under 20 hours a week doesn't meet the minimum, and a 40-hour role that isn't related to your degree doesn't qualify either.

How each kind of work is reported

Sources for the table: SEVP Portal Help, Update Employer Information; SEVIS Help Hub, Add, Edit, Delete OPT Employer; Study in the States, STEM OPT reporting requirements; Reporting Volunteer Positions During OPT Employment.

Timing. "While on OPT, the student must report to the DSO within 10 days any changes in the student's name or address, and employment information." (SEVIS Help Hub, F-1 OPT) The SEVP Portal guide explains where official sources differ on this deadline. Step-by-step portal instructions are in How to report a new employer.

Records and evidence to keep

Most of these come straight from SEVP's guidance. Keep them for every unpaid, volunteer or part-time role:

• Proof of hours from the organization. For unpaid work, "evidence acquired from the student's employer to verify that the student worked at least 20 hours per week" (§7.2.1, SEVP Policy Guidance 1004-03).
• Timesheets for a variable schedule, so you can show the monthly average (§7.1.5).
• Evidence for each position: "the position held, proof of the duration of that position, the job title, contact information for the student's supervisor or manager, and a description of the work" (§7.2.4).
• A letter, if the link to your degree isn't obvious. SEVP recommends "a signed letter from his or her hiring official, supervisor, or manager stating how the student's degree is related to the work performed" (§7.2.4).
• Follow your DSO's request. SEVP's 2019 guidance says it supersedes earlier SEVP information on the degree link, so treat these 2010 suggestions as record-keeping ideas and follow your DSO's request.
• Your written explanation of how the role relates to your major, which the DSO must review and keep (SEVP Policy Guidance, Sept. 27, 2019).
• Your reports. "The student should keep a record of all reports made to the DSO and the method by which the reports are made." (§7.3.2)
• On STEM OPT: each signed Form I-983, including the compensation it lists, and every evaluation.

More on what to keep, and for how long, is in Immigration records to keep.

When the work doesn't qualify: what happens to your unemployment days

A role that doesn't qualify doesn't stop the count.

• SEVP: "Non-qualifying positions do not stop the accrual of unemployment, which is limited to a total of 90 days during OPT." It adds: "If you have been unemployed for more than 90 days, you must leave the United States or be subject to removal, even if you have volunteered while unemployed." (Reporting Volunteer Positions During OPT Employment)
• "Each day (including weekends) during the period when OPT authorization begins and ends that the student does not have qualifying employment counts as a day of unemployment." (§7.1.6, SEVP Policy Guidance 1004-03)
• The limits: no more than 90 days in total on post-completion OPT, and 150 in total for students granted the 24-month STEM extension, counting both periods (8 CFR 214.2(f)(10)(ii)(E)).

Fictional example: volunteering below 20 hours

Fictional dates. Not your dates. Lin's OPT EAD starts Wednesday, July 1, 2026. From that day she volunteers 12 hours a week at a nonprofit, in work related to her degree. On Monday, August 17, 2026 she starts a paid job in her field at 25 hours a week.

• The volunteering is related, but at 12 hours a week it doesn't meet the 20-hour minimum.
• So every day from July 1 through Sunday, August 16 counts: 47 days. If she has no other days, she has 43 left of the 90.
• If her volunteering had been at least 20 hours a week, lawful and related to her degree, it could count as OPT employment under the Policy Manual's test.

If your count is getting close to the limit, see What happens if you go over 90 days of unemployment. SEVIS counts from the employer dates that were reported, which is explained in the SEVP Portal guide.

Keeping track in EADly

EADly is a private, local-first app for iPhone and Android:

• Employment records. Save each job with its dates, a type (full time, part time or volunteer/unpaid) and whether it's related to your field. EADly Free saves every F-1 job (OPT, STEM OPT and CPT).
• Unemployment-day counter. It counts the days that no saved job marked as related to your field covers. It doesn't check hours: a saved part-time or volunteer job you mark as related stops the counter whatever its weekly hours. Compare it with what your DSO sees in SEVIS.
• STEM OPT checks. During STEM OPT, including a pending extension, EADly won't save a job typed as volunteer/unpaid and asks you to confirm the employer is in E-Verify.
• Document Vault. Keep timesheets and letters encrypted on your phone and link them to a job. EADly Free stores one file; EADly Plus removes the file-count limit.

What it doesn't do: EADly doesn't decide whether a role qualifies, whether it meets labor laws or whether you are in status, and it doesn't report anything to your DSO, SEVIS or USCIS. Nothing is sent to a server unless you turn on backup.

Get EADly on the App Store or Google Play. It's a free download.

Common questions

Sources

All checked October 22, 2026. The date in brackets is the date each page showed.

• USCIS Policy Manual, Vol. 2, Pt. F, Ch. 5: https://www.uscis.gov/policy-manual/volume-2-part-f-chapter-5 [current as of 10/02/2026; checked October 22, 2026]
• USCIS, Optional Practical Training (OPT) for F-1 Students: https://www.uscis.gov/working-in-the-united-states/students-and-exchange-visitors/optional-practical-training-opt-for-f-1-students [last reviewed 11/25/2024; checked October 22, 2026]
• USCIS, Optional Practical Training Extension for STEM Students (STEM OPT): https://www.uscis.gov/working-in-the-united-states/students-and-exchange-visitors/optional-practical-training-extension-for-stem-students-stem-opt [last reviewed 01/30/2026; checked October 22, 2026]
• 8 CFR 214.2(f)(9)(i), (f)(10)(ii)(A), (f)(10)(ii)(C)(5) and (8), and (f)(10)(ii)(E), eCFR as of Sept 14, 2026: https://www.ecfr.gov/on/2026-09-14/title-8/chapter-I/subchapter-B/part-214/subpart-A/section-214.2 [eCFR version of 09/14/2026; checked October 22, 2026. We cite this version because USCIS says it "will proceed under the previous regulatory provisions" while a court order postpones the July 17, 2026 rule: https://www.uscis.gov/i-765]
• SEVP Policy Guidance 1004-03, Update to Optional Practical Training: https://www.ice.gov/doclib/sevis/pdf/opt_policy_guidance_042010.pdf [dated 04/23/2010; checked October 22, 2026]
• SEVP Policy Guidance, Practical Training: Determining a Direct Relationship Between Employment and a Student's Major Area of Study: https://www.ice.gov/doclib/sevis/pdf/optDirectlyRelatedGuidance.pdf [dated 09/27/2019; checked October 22, 2026]
• ICE, Practical Training: https://www.ice.gov/sevis/practical-training [updated 12/10/2024; checked October 22, 2026]
• ICE, SEVIS Employment (F-1 on-campus FAQ): https://www.ice.gov/sevis/employment [updated 12/30/2025; checked October 22, 2026]
• Study in the States, Reporting Volunteer Positions During OPT Employment: https://studyinthestates.dhs.gov/2018/07/reporting-volunteer-positions-during-opt-employment [posted 07/05/2018, with a note that the content may be outdated; checked October 22, 2026]
• Study in the States, SEVIS Help Hub, F-1 Optional Practical Training (OPT): https://studyinthestates.dhs.gov/sevis-help-hub/student-records/fm-student-employment/f-1-optional-practical-training-opt [last updated 05/19/2025; checked October 22, 2026]
• Study in the States, SEVIS Help Hub, F-1 Add, Edit, Delete OPT Employer: https://studyinthestates.dhs.gov/sevis-help-hub/student-records/fm-student-employment/f-1-add-edit-delete-optional-practical [last updated 04/28/2025; checked October 22, 2026]
• Study in the States, SEVP Portal Help, Update Employer Information: https://studyinthestates.dhs.gov/sevp-portal-help/maintain-information/update-employer-information [last updated 05/25/2023; checked October 22, 2026]
• Study in the States, STEM OPT reporting requirements (students): https://studyinthestates.dhs.gov/stem-opt-hub/for-students/students-stem-opt-reporting-requirements [last updated 07/06/2026; checked October 22, 2026]
• Study in the States, Students: Determining STEM OPT Extension Eligibility: https://studyinthestates.dhs.gov/stem-opt-hub/for-students/students-determining-stem-opt-extension-eligibility [last updated 03/25/2026; checked October 22, 2026]
• U.S. Department of Labor, Wage and Hour Division, Fact Sheet #71: Internship Programs Under the Fair Labor Standards Act: https://www.dol.gov/agencies/whd/fact-sheets/71-flsa-internships [updated January 2018; checked October 22, 2026]

This article summarizes official U.S. government sources and is not legal or immigration advice. EADly is not a law firm and is not affiliated with USCIS, DHS, ICE or the Department of Labor.

More guides

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