PSLF in 2026: Employer-Eligibility Changes, Buyback and How to Protect Your Count
Public Service Loan Forgiveness survived a rule that would have let the government disqualify employers, but RAP, the Tiered Standard default and a new buyback formula changed how you get to 120. Here's what counts now.
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📐 Figures verified Sep 28, 2026 against the Education Department's October 2025 PSLF final rule and fact sheet, its July 13, 2026 notice removing the employer attestation after the courts vacated that rule, NASFAA's litigation tracker for the August 27 appeals, Public Law 119-21 (RAP counts for PSLF; Tiered Standard doesn't), Federal Student Aid's PSLF pages and the RAP, IBR and 2026 poverty-line figures in our registry. How we check numbers →
PSLF still forgives the rest of your Direct loans after 120 qualifying payments while you work full time for a qualifying government or nonprofit employer. The 2025 employer rule never took effect: federal courts vacated it on June 30, 2026, and it has no effect unless an appeals court revives it. What changed: RAP counts, Tiered Standard doesn't, and buyback no longer uses SAVE's formula.
Numbers That Matter
| Figure | Amount | Source | Verified |
|---|---|---|---|
| Qualifying payments for forgiveness | 120, while working full time (30+ hours a week) for a qualifying employer | Federal Student Aid | Sep 28, 2026 |
| 2025 employer-eligibility rule | Vacated June 30, 2026, a day before its July 1 start; employer attestation removed from the form | Federal Student Aid notice, Jul. 13, 2026 | Sep 28, 2026 |
| RAP payment | 1% to 10% of income, $10 minimum; counts toward PSLF | P.L. 119-21 | Sep 28, 2026 |
| Tiered Standard plan | Does not count toward PSLF | P.L. 119-21 | Sep 28, 2026 |
| Buyback pricing | IBR, PAYE or ICR formula since Mar. 31, 2026 (SAVE formula dropped) | Federal Student Aid | Sep 28, 2026 |
| SAVE forbearance months | Don't count; interest has accrued since Aug. 1, 2025 | Federal Student Aid | Sep 28, 2026 |
What Changed in 2026, and What Didn't
The core of PSLF is set by law and hasn't moved: 120 qualifying monthly payments on Direct loans, made under a qualifying plan while you work full time for a government agency, a 501(c)(3) nonprofit or another qualifying nonprofit, and whatever is left is forgiven tax-free. Three things around it did change this year:
- The employer rule came and went. A 2025 rule would have let the Education Secretary disqualify employers found to have a "substantial illegal purpose." Courts vacated it the day before it started.
- The plan menu changed on July 1. RAP arrived and counts. Tiered Standard, the new default for new loans, doesn't. SAVE is gone, and PAYE and ICR close by July 1, 2028.
- Buyback got pricier for many. Since March 31, 2026, bought-back months are priced with IBR, PAYE or ICR formulas instead of SAVE's lower one.
The Employer Rule: Vacated, Under Appeal
The Education Department finalized the rule on October 31, 2025, after a March 2025 executive order. It listed conduct such as aiding violations of federal immigration law, supporting terrorism, certain medical procedures on minors and illegal discrimination, and it would have made employers certify, under penalty of perjury, that they had engaged in none of it from July 1, 2026. A disqualified employer would have lost eligibility for 10 years unless the Department approved a corrective plan; payments made before a disqualification would have kept counting.
On June 30, 2026, federal courts in Washington, D.C., and Massachusetts vacated the rule; the D.C. court held that the Department exceeded its authority because the law makes 501(c)(3) employment qualify. The Department removed the attestation from the PSLF form in July. It appealed both rulings on August 27, 2026, so the fight continues in the First and D.C. Circuits, but nothing changes for borrowers unless an appeals court revives the rule. Keep certifying as usual.
Which Repayment Plans Count Now
| Plan | Counts for PSLF? | Notes |
|---|---|---|
| Repayment Assistance Plan (RAP) | Yes | 1% to 10% of income, $10 minimum; the only income-driven plan for new loans from July 1, 2026 |
| Income-Based Repayment (IBR) | Yes | For borrowers who took no new loan on or after July 1, 2026 |
| 10-year Standard | Yes | Counts, but it pays the loan off in 10 years, leaving little to forgive |
| PAYE and ICR | Yes, for now | Closed to new loans; they end by July 1, 2028 |
| Tiered Standard | No | The default for new loans and consolidations made from July 1, 2026 |
| SAVE forbearance | No | Recoverable only through buyback |
The trap is the default. A new federal loan or a consolidation made on or after July 1, 2026 moves every loan you have to Tiered Standard unless you choose RAP, and Tiered Standard months don't count. Parent PLUS borrowers who didn't consolidate before July 1, 2026 lost the route to an income-driven plan; the 10-year Standard plan still counts but leaves little to forgive.
PSLF Buyback After the March 2026 Change
Buyback lets you pay for months spent in deferment or forbearance and turn them into qualifying payments. You can use it once you have 120 months of qualifying employment, and only when buying the months back would bring you to 120. The price is what you'd have paid under an income-driven plan for those months. Since March 31, 2026 the Department prices them with IBR, PAYE or ICR formulas; for many borrowers who sat in SAVE forbearance that means a higher bill than the SAVE formula would have produced.
Buyback exists in regulation, not in the statute, so rulemaking could change it again. A bipartisan bill introduced in September 2026 would count SAVE forbearance months without a buyback, but it is only a proposal.
Protect Your Count: A Checklist
- Certify employment at least once a year and every time you leave a job, using the PSLF Help Tool on StudentAid.gov. It's far easier while your supervisor and HR office still know you.
- Check your qualifying-payment count after every certification. If months are missing, ask for reconsideration with your records.
- Stay on a plan that counts. Choose RAP, or IBR if you're eligible, and never let a new loan or consolidation drop you into Tiered Standard by default.
- Leave SAVE forbearance on purpose. Those months don't count; pick a plan now and plan a buyback for the gap.
- Work at least 30 hours a week for qualifying employers; hours at two qualifying employers can be combined.
- Keep your own file: W-2s and pay stubs for each employer and its EIN, certification confirmations and payment histories.
Worked Example: Buy Back or Keep Paying?
Jordan has taught since 2016, so she has 120 months of qualifying employment, but only 108 qualifying payments: 12 months sat in SAVE forbearance. She is single, earns $58,000, first borrowed after July 1, 2014 and owes about $52,000.
- Buy back the 12 months: at the IBR formula (10% of income above 150% of the $15,960 poverty line) that's about $283.83 a month, or $3,405.96. She reaches 120 and the remaining balance, about $52,000, is forgiven tax-free once the Department processes it.
- Keep paying on RAP: 5% of $58,000 is about $241.67 a month, or $2,900.04 over the 12 months it takes to reach 120.
- The trade-off: buyback costs about $505.92 more but finishes a year sooner, and it's the only route if she plans to leave public service before then.
Buyback prices depend on the income on file for the months bought back; this uses her current income and the 2026 poverty line for a household of one. Jordan is an illustration.
Decision Rules
If this, then that
- If you worry your employer will be disqualified → keep certifying; the rule is vacated and has no effect unless an appeals court revives it.
- If you're taking a new loan or consolidating after July 1, 2026 → choose RAP on the application so you don't land in Tiered Standard.
- If you have 120 months of qualifying employment but fewer than 120 payments → price a buyback against the months of payments still ahead.
- If you're still in SAVE forbearance → pick a qualifying plan now; the months in forbearance don't count.
- If you're changing jobs → certify with your old employer before your last day.
Mistakes to avoid
- Stopping certifications because of headlines about the employer rule.
- Consolidating after July 1, 2026 without choosing RAP.
- Assuming SAVE forbearance months will count on their own.
- Refinancing into a private loan, which ends PSLF for good.
- Waiting years to certify a past job whose HR office may no longer exist.
Related: RAP vs IBR vs Tiered Standard compares the plans; the SAVE exit checklist covers leaving forbearance; the consolidation trap explains what a new loan does to old ones; and student loan forgiveness covers every forgiveness route.