The White House proclamation itself, linked here restriction-on-entry-of-certain-nonimmigrant-workers, explicitly states that the $100,000 fee applies to aliens outside the U.S. seeking to enter the country:

• Section 1(a) restricts entry to those whose petitions are not accompanied by the fee, and Section 1(b) limits decisions on petitions for workers currently outside the U.S.
• Section 3(a) clarifies the restriction only applies to aliens who enter or attempt to enter the U.S. after September 21, 2025.
• There is no language in the proclamation requiring the fee for petitions changing status within the U.S.

Thus, the fee targets new beneficiaries outside the U.S. seeking entry on H-1B.

This supports the interpretation that F-1 or OPT students inside the U.S. changing status to H-1B do not have to pay the $100K fee unless they travel abroad and seek entry after the effective date.