Major Rulemaking Concludes, Borrowers Brace for 2026 Changes

July 2025 arrived with a major milestone in the multi-year overhaul of federal student loan forgiveness programs. On July 2, 2025, the Department of Education officially concluded its negotiated rulemaking process, publishing a final summary on ed.gov/news/july2025-pslf-final-session that detailed new regulatory language impacting PSLF.

This marked the culmination of discussions that began back in February, accelerated by the March 7, 2025 executive order, and shaped by months of public comments through spring. The final draft rules clarified how “substantial illegal purpose” would be defined for employer reviews, explicitly stating that minor infractions or technical grant issues wouldn’t generally trigger PSLF disqualifications.

Financial publications like MarketWatch (July 3, 2025) highlighted that while the Department aimed to tighten oversight on employers, it retained critical protections for borrowers who had already secured Employment Certification Forms. Under the new language, certifications approved before any employer investigation would continue to safeguard those payments toward the 120 needed for forgiveness.

At the same time, the Department reminded borrowers that these rules are scheduled to formally take effect on July 1, 2026, giving everyone roughly a year to solidify certifications and ensure compliance under current frameworks. The DOE also announced expanded borrower outreach starting later this summer, including direct emails and webinars to help workers understand any new employer documentation expectations.

For many public service employees, this meant July became a perfect moment to conduct a “PSLF audit”—downloading complete payment histories from studentaid.gov, requesting fresh ECFs from HR, and saving confirmation emails or servicer letters in dedicated folders. Financial advisors noted that doing this now could lock in critical periods before stricter regulatory scrutiny begins.

The month closed with a mix of relief and renewed urgency. Borrowers felt reassured that existing progress was largely protected, yet recognized the importance of carefully managing their records over the next 12 months. By staying proactive, they positioned themselves to cross the finish line before more rigorous oversight of employer practices officially kicks in next summer.


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