The Education Department has quietly implemented several new restrictions on student loan forgiveness during the last six weeks. While they don’t outright block loan forgiveness eligibility, the changes do create significant new barriers. And the reforms will make it harder (or, in some cases, impossible) for many borrowers to discharge their federal student loans.

Most of the new restrictions relate to the new Repayment Assistance Plan, or RAP, a new income-driven repayment plan created under the One Big, Beautiful Bill Act. RAP went live in July, and tens of thousands of borrowers have already signed up . The department has been mounting a public relations campaign to convince borrowers that they should enroll. But RAP comes with some significant restrictions that could limit the ability of borrowers to eventually get their student loans forgiven.

Here’s what’s going on, and what federal student loan borrowers need to know.

New Rules For Student Loans Under Income-Driven Repayment Plans

RAP, like all income-driven plans, offers eventual student loan forgiveness after a borrower has spent in years in repayment. But compared to other plans, RAP requires that borrowers make payments on their student loans for far longer before they can discharge their student loans. While the PAYE and “new” (post-2014) IBR plans offer loan forgiveness after 20 years, and ICR and the older version of IBR have a 25-year term, RAP only permits student loan forgiveness after 30 years in repayment.

But RAP also has its benefits, including interest and principal incentives. Borrowers whose monthly payments are less than the amount of interest accrual can get any excess interest waived while enrolled in RAP, preventing their loan balance from continuing to increase. In addition, up to $50 each month can be dedicated to loan principal, ensuring that their loan balance gradually decreases.

However, one new restriction associated with RAP has flown under the radar a bit. To receive these interest and principal benefits, and for any payment to count toward eventual student loan forgiveness, the borrower must make a payment on-time. The payment must be made on or before the billing due date, within the applicable billing cycle.

“Assuming all payments are made on time and in full and that you don’t take any breaks (like a deferment or forbearance) after entering RAP, then your total outstanding balance will never go higher than your total outstanding balance when you entered RAP,” says online Education Department guidance ." Qualifying payments toward student loan forgiveness must also be made “on time.”

That means that under RAP, if a borrower makes a payment even one day late, or an auto-debit date falls on a weekend or holiday, that payment may not count toward student loan forgiveness, and borrowers could lose any interest and principal benefit for that month. These restrictions haven’t historically been true for the IBR plan, but starting in 2027, that will also change.

“Starting in spring 2027, payments for the IBR Plan must be made on time and in full in order for you to receive the interest subsidy,” says department guidance.

New Limits On Getting Student Loans Forgiven Through PSLF

RAP, like all income-driven repayment plans, is a qualifying repayment plan for Public Service Loan Forgiveness, or PSLF. PSLF allows borrowers to get their federal student loans discharged in as little as 10 years if they repay those loans under an IDR plan while working as a full-time employee for qualifying nonprofit or public organizations.

But borrowers repaying their student loans under RAP and pursuing PSLF should be aware of a new restriction that the Education Department quietly put into effect last month. For a RAP payment to count toward PSLF, the payment must be made on time, and in full.

“Generally, payments made under the RAP are eligible for Public Service Loan Forgiveness (PSLF) as long as the payment is made on time and in full,” says new Education Department guidance on the RAP program.

“For borrowers with any loan disbursed on or after July 1, 2026, and who are enrolled in the Repayment Assistance Plan, only payments made on or before the due date in the full amount due qualify for PSLF,” echoes the department’s updated online guidance for the PSLF program .

Previously, borrowers had a roughly two-week grace period to make their payment, and slightly late payments could still be considered “on-time” for purposes of PSLF, and, thus, count toward student loan forgiveness. But under RAP, that will not be true. And the department’s new online PSLF guidance suggests that may even no longer be true for borrowers pursuing in PSLF while enrolled in other income-driven repayment plans.

“For borrowers with only loans disbursed before July 1, 2026, a qualifying payment is a full, on‑time monthly payment you make while working full time for a qualifying employer,” says the guidance. “The payment must be for the amount listed on your bill, made on or before the due date, and made after October 1, 2007.”

Ambiguous Changes For Student Loans Under PSLF Buyback

PSLF Buyback is a related program that gives borrowers the opportunity to “buy back” certain deferment and forbearance periods that would have counted toward student loan forgiveness if the borrower had been in repayment, but the periods didn’t because they were in a non-payment status. If approved for buyback, borrowers would make a lump sum payment equivalent to what they would have paid under an income-driven repayment plan for that deferment or forbearance period.

But the Education Department has imposed new, special restrictions for PSLF Buyback as it relates to the RAP program.

“Except for repayment periods when a borrower is repaying under the Repayment Assistance Plan under § 685.209, for any months in which a borrower postponed monthly payments under a deferment or forbearance and was employed full-time at a qualifying employer as defined in this section but was in a deferment or forbearance status besides those listed in paragraph (c)(2)(v) of this section, the borrower may obtain credit toward forgiveness for those months, as defined in paragraph (d) of this section, for any months in which the borrower— (i) Makes an additional payment equal to or greater than the amount they would have paid at that time on a qualifying repayment plan or (ii) Otherwise qualified for a $0 payment on an income-driven repayment plan under § 685.209,” reads the PSLF Buyback regulations following recent amendments after the department implemented the One Big, Beautiful Bill Act on July 1.

The department has also updated its PSLF Buyback webpage to include an eligibility exclusion for periods “while in repayment under the Repayment Assistance Plan or Tiered Standard” plan.

The language in both the amended regulation and the department’s updated web guidance is ambiguous enough that there could be multiple plausible interpretations. For example, the regulation could be read to mean that periods when the borrower is making payments under RAP would not be eligible for PSLF Buyback, which would make sense, since repayment periods generally don’t qualify for buyback. But another plausible reading could mean that borrowers who go into a deferment or forbearance while they are enrolled in RAP would not be able to subsequently get those deferment or forbearance periods counted toward student loan forgiveness through the PSLF Buyback program, even if they would otherwise be eligible buyback periods. If true, that is a potentially major restriction that has flown under the radar.

Getting Student Loans Forgiven May Be Harder For Borrowers Who Leave RAP Program

Historically, borrowers who move from one income-driven repayment plan to another have been able to transfer the student loan forgiveness credit they earned under the first IDR plan to the new IDR plan. That way, they aren’t starting over on their repayment term. For example, a borrower who has made payments for 10 years on their student loan under the ICR plan should be able to transfer that 10 years of credit if they switch to the IBR plan. In doing so, they could still get their student loans forgiven in 15 more years, rather than starting over at the beginning of the 25-year term for IBR (factoring in their 10 years of earned credit).

But now, that isn’t entirely the case for RAP. Borrowers can still bring their IBR, ICR, and PAYE student loan forgiveness credit to RAP, where it will count toward RAP’s 30-year repayment term. But payments that borrowers make under RAP will only count toward RAP’s 30-year term. If a borrower subsequently wants to switch back to another income-driven repayment plan, like IBR, those RAP payments will not count toward IBR’s 25-year student loan forgiveness term.

“If you’re enrolled in the PAYE Plan, which has a 20-year repayment period, and you subsequently enroll in RAP, which has a 30-year repayment period, then your payments under the PAYE Plan will count toward discharge under RAP, but your repayment period would increase from 20 to 30 years,” explains the Education Department in its online guidance. “If you’re eligible for the IBR, ICR or PAYE plans and you enroll in RAP, you’re permitted to reenroll in the IBR, ICR or PAYE plan. However, payments made under RAP won’t count toward discharge under the IBR, ICR or PAYE plans.”

Many Parent PLUS Borrowers Now Cannot Get Student Loans Forgiven

Under the new regulations implemented under the One Big, Beautiful Bill Act, Parent PLUS borrowers who did not consolidate their student loans through the federal Direct consolidation program before July are now effectively cut off from all income-driven repayment plans. And Parent PLUS borrowers who take out any new student loans or consolidate their existing loans going forward will also be cut off from income-driven repayment.

If “all of your loans are first disbursed before July 1, 2026,” and the borrower consolidated those loans prior to that date, “you’ll retain access to many of the existing fixed payment repayment plans, as well as the Income-Based Repayment (IBR) and Income-Contingent Repayment (ICR) plans,” says the Education Department in its online guidance. “If you have any type of Direct Loan—including a Direct Consolidation Loan—that is first disbursed on or after July 1, 2026, then your access will be limited to only the Tiered Standard Plan.”

The Tiered Standard repayment plan is not an eligible plan for PSLF, and payments made under that plan also won’t count toward student loan forgiveness under income-driven repayment plans. Thus, Parent PLUS borrowers who did not consolidate their student loans before July 1, or who take out any new loans or consolidate their loans going forward, will effectively become ineligible for student loan forgiveness under IDR plans, as well as under PSLF.