CPT authorization is strongly recommended for all unpaid internships, whether the student does or does not need to provide employment authorization documents to the company. The F-1 regulations are written in such a way that CPT is an authorization to do practical training as part of the curriculum for the academic program, and as such is significant in more ways than simply for the employer to verify employment eligibility. CPT authorization is more than just permission to get paid.
You should have CPT authorization for unpaid internships for the following reasons:
- CPT authorization by the university serves to demonstrate that this practical experience is part of the curriculum.
- CPT authorization is a way of reporting in SEVIS the student’s activity, employment, and location where they are working and therefore maintaining their status.
- If ever a student is doing a job on an unpaid basis that someone would be hired and paid for, employment authorization in the form of CPT, OPT, etc. is advised.
- If the unpaid internship at some point changes into a paid one (or if your employer decides to compensate you for your work in any way – for example, give you a monetary gift), you won’t be able to accept the payment if your internship was not authorized as CPT. Please keep in mind that F-1 students cannot be retroactively remunerated or in any way compensated for work done in an unpaid internship if they did not obtain work authorization prior to when the work was performed.
Based on the above, we recommend that you apply for CPT authorization if you have an internship offer (paid or unpaid) that meets CPT eligibility criteria.
If the position is unpaid and for some reason it is not possible for you to obtain CPT authorization, please make sure that your prospective supervisor is aware of U.S. Department of Labor regulations concerning unpaid internships and that you have assurances (preferably written) to that effect before you accept the position. We also recommend that at the end of your internship you ask your employer to provide you with a letter confirming that there was no remuneration or any other type of compensation provided in any form during the dates you were participating in the internship. Please keep such a letter for your permanent records.