PSLF Employer Rule Vacated: What It Means for You
Guides · Updated October 17, 2026 · 2 min read
General information, not legal, tax or financial advice. We are not the U.S. Department of Education or the IRS and have no access to your loan account. Check StudentAid.gov. Sources read October 17, 2026; items marked expected may change. Examples use made-up numbers. This page contains no affiliate links.
Short answer: According to NASFAA reporting, a federal judge vacated the Department of Education's PSLF final rule on employer eligibility on June 30, 2026, hours before its July 1, 2026 effective date, so the changes did not take effect and the current qualifying-employer definition remains in effect. NASFAA reported on August 28, 2026 that the Department appealed to the First Circuit and that the vacatur remains in effect while the appeal is pending.
Background
The rule (published October 31, 2025, effective July 1, 2026) would have added a provision excluding employers found to have a "substantial illegal purpose," with determinations by the Secretary. The court decision's memorandum quotes the proposed new definition of "qualifying employer."
What the court decision says (per NASFAA)
The judge ruled the rule contrary to law, beyond the Department's statutory authority, arbitrary and capricious, and in violation of the First Amendment.
What this means in practice (not advice)
- Under the vacatur, PSLF continues to be administered under the existing regulations.
- The outcome of the appeal is unknown; we expect further news and don't predict it.
- The certification form: the Department had sought clearance to revise it before July 1; we did not verify what form is in use now.
What to do
Keep records of your employment certifications and check StudentAid.gov for the current PSLF status before relying on this page.
Related
RAP counts for PSLF · Tiered Standard does not
FAQ
Is the rule dead?
Not necessarily; an appeal was filed.
Does this affect my qualifying payments?
Not on the facts above; check your account.
What we could not verify
- StudentAid.gov's PSLF pages could not be read (they render by script), so the Department's own current position is unverified. This page relies on a secondary source (NASFAA) and excerpts of the court decision.
- Status of the appeal after August 28, 2026.
- Which certification form is currently in use.
Sources
- NASFAA, Federal Court Vacates PSLF Final Rule on Employer Eligibility, Hours Before July 1 Effective Date — https://www.nasfaa.org/news-item/39289/Federal_Court_Vacates_PSLF_Final_Rule_on_Employer_Eligibility_Hours_Before_July_1_Effective_Date (search excerpt read October 17, 2026; secondary source)
- NASFAA, ED Appeals Court Decision That Struck Down PSLF Final Rule (August 28, 2026) — https://www.nasfaa.org/news-item/39696/ED_Appeals_Court_Decision_That_Struck_Down_PSLF_Final_Rule (search excerpt; secondary source)
- Memorandum of Decision, June 30, 2026 (court document hosted by the Rhode Island Attorney General) — https://riag.ri.gov/media/8881/download (search excerpt only)
- Federal Register, October 31, 2025, PSLF final rule — https://www.govinfo.gov/content/pkg/FR-2025-10-31/html/2025-19729.htm (search excerpt only)