Draft Rules Released Ahead of Final Comments

On May 30, 2025, the DOE published the first full draft of new PSLF regulations emerging from months of negotiated rulemaking and the March executive order. These drafts, uploaded to the official ed.gov/rulemaking portal, included detailed language on defining “substantial illegal purpose” and safeguarding good-faith certifications.

MarketWatch (June 2, 2025) reported that while the rules toughened compliance standards for employers, they also contained explicit protections for borrowers who secured approved ECFs prior to any new investigations. This was seen as a partial win for unions and state agencies that lobbied heavily through public comment sessions.

By June 15, 2025, the Department opened a 60-day comment window, inviting both individual borrowers and institutional stakeholders to weigh in. Advocacy groups quickly launched campaigns encouraging public service workers to submit personal stories, reinforcing the importance of not punishing employees for organizational mistakes.

Financial planners used this period to run fresh PSLF “audits” for clients, making sure SAVE enrollments, qualifying payment counts, and employment records all aligned cleanly. With final rules expected by early 2026 and a planned effective date of July 1, 2026, there was still time for proactive borrowers to secure their paths.

The combination of draft regulatory language and large-scale IDR credits meant many saw June as both a final chance to influence policy and an ideal moment to tighten personal documentation, ensuring long PSLF journeys reached their intended finish line.

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