The Education Department has taken steps in recent weeks that may make harder for borrowers pursuing student loan forgiveness to reach their end goal of a discharge. Through administrative actions, legal appeals, and regulatory implementation, the department seems to be sending a clear message to borrowers that if you want to get your student loans forgiven, it may be tougher now than it was before. And things may be getting even harder.

While borrowers are still able to get their student loans discharged , and the department continues the grant people loan forgiveness under popular programs like Public Service Loan Forgiveness, the future is as uncertain as ever. Here’s a breakdown of what’s going on, and what borrowers should know.

Education Department Takes Big Step To Reinstate Restrictions For Student Loans On Track For PSLF

Borrowers celebrated a major victory earlier this summer when two separate federal courts ruled that the Education Department’s proposed regulations to limit relief under the Public Service Loan Forgiveness program, or PSLF, were unlawful. The department, in response to an executive order issued by President Trump last year, had drafted new rules that would give U.S. Secretary of Education Linda McMahon sweeping powers to disqualify employers from the program if, in her determination, the employer was engaged in activities that had a “substantial illegal purpose.” Borrowers working for such an employer would be cut off from student loan forgiveness, with no right of appeal.

Nonprofit groups, labor unions, state governments, and municipalities filed lawsuits against the Education Department, arguing that the new PSLF rules were illegal. Congress did not give the department any such authority in the statutes governing the PSLF program, they argued. And the regulations, if implemented, could allow the department to target constitutionally protected speech or freedom assembly. Two federal courts agreed, and blocked the proposed rules in June, just before they were about to take effect.

But last week, the department filed notices of appeal in both cases, signalling that the battle over these student loan forgiveness restrictions is far from over. Nothing changes for borrowers right now, but the legal fight over whether the department can stop student loans from getting forgiven due to the actions of a qualifying PSLF employer may now drag on through next year as the appeal process plays out.

Education Department Pulls Student Loans Back From Student Loan Forgiveness Eligibility

But appealing the court rulings blocking proposed new restrictions aren’t the only adverse actions the Education Department is taking against borrowers in the PSLF program. The department is also taking administrative steps to rollback PSLF credits, jeopardizing or delaying the ability of some borrowers to get their student loans forgiven.

Earlier in August, borrowers began reporting sudden drops in their qualifying PSLF payment counts, with official notices indicating that their PSLF payments had been subject to a “reduction.” Borrowers must make 120 qualifying payments, the equivalent of 10 years, to get their student loans forgiven under the program. All borrowers could see was a banner message on their StudentAid.gov accounts saying that their PSLF payment counts were incorrect and were getting updated.

The Education Department eventually acknowledged that officials were trying to correct data irregularities, which they blamed on the Biden administration, for erroneous PSLF payment counts. It appears that the department was trying to reverse PSLF credit awarded for periods that should not have otherwise counted toward student loan forgiveness, such as payments made under non-eligible repayment plans. But other borrowers have reported that they have lost legitimately-earned PSLF credit for periods when they were meeting all of the PSLF program’s requirements.

The department has not issued any other public guidance, leaving borrowers in the dark about the scope of the reversals and whether they’re going to get any of their reversed PSLF credit back. If they don’t, they may now be much further away from being able to get their student loans discharged (but they also aren’t getting any refunds from the department for legitimate, qualifying payments they made that have now been re-coded as ineligible for PSLF).

Student Loans In The SAVE Plan Are About To Be Kicked Off

Meanwhile, the Education Department continues to send out notices to borrowers with student loans in the SAVE Plan that they have 90 days to switch to a different income-driven repayment plan. If they don’t, the notices say, they will be put into a Standard plan, which would be unaffordable for many borrowers and won’t count toward eventual student loan forgiveness.

“A recent legal settlement ended the Saving on a Valuable Education (SAVE) Plan, and it is no longer available to borrowers,” reads the official notice. “As a result of the settlement, Aidvantage was directed by the U.S. Department of Education (ED) to move all borrowers out of the SAVE Plan. You must now select a new repayment plan. If you’re currently enrolled in the SAVE Plan but don’t submit a new application for a different repayment plan within 90 days, you will be placed on the Standard Repayment Plan.” Other loan servicers are sending out similar messages.

The notices have been going out in batches roughly every two weeks since early July. In just a few weeks from now, the first borrowers to have received the SAVE plan notices on July 1 will be reaching the 90-day threshold. At that point, if they haven’t enrolled in a different repayment plan, they’ll be put into a Standard plan, spiking their monthly payments. And even borrowers who comply with the directive may be in for a shock , as payments under other available income-driven repayment plans are almost universally higher than the SAVE plan, and those plans may also require additional years in repayment before borrowers can get their student loans forgiven.

New Restrictions On How Student Loans Must Be Paid To Qualify For Loan Forgiveness

The Education Department has also quietly implemented new rules that may make it more difficult to progress toward eventual student loan forgiveness. As of July 1, borrowers must make payments on or before their due dates for any such payment to count toward PSLF or loan forgiveness under income-driven repayment plans. These rules are not just limited to the new Repayment Assistance Plan, or RAP. They cover all income-driven plans, according to the department.

“Late payments may be reported to credit bureaus and could damage your credit history,” says new department web guidance . “Also, late payments no longer count toward IDR discharge or PSLF starting on July 1, 2026. If you don’t make your full monthly payment on time for any month, you won’t receive credit toward discharge for that month.”

Previously, borrowers could make a payment a little late and it would still count toward eventual student loan forgiveness. But that will no longer be the case, and many borrowers may not even be aware of the change, as the department’s new guidance is buried at the bottom of a single long web page on its sprawling website. Borrowers hoping to get their student loans forgiven should ensure that all payments are made on or before their due dates going forward if they are pursuing a discharge through IDR plans or PSLF, and that includes if the due date falls on a weekend or holiday.