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)

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