PSLF Rule Timeline: From Executive Order to Dropped Appeals
Quick answer
The PSLF employer rule went from executive order to final rule in 2025, was challenged in court within days, was vacated in June 2026 before taking effect, and ended in October 2026 when the government dropped all its appeals. This timeline lays out each step.
Key takeaways
- 2025: An executive order on PSLF led to new rulemaking.
- October 31, 2025: The final rule was published.
- November 3-4, 2025: Three lawsuits were filed.
- June 30, 2026: Courts vacated the rule; it never took effect on July 1.
- October 21-22, 2026: The government dropped all three appeals.
In this article
The fight over who counts as a public service employer for student loan forgiveness lasted about a year from start to finish. Here is how it unfolded.
2025: The executive order
A 2025 executive order from President Trump directed changes to Public Service Loan Forgiveness. The Education Department then began rulemaking aimed at excluding employers involved in what it called illegal activity.
October 31, 2025: Final rule published
The department published its final rule. Under it, the agency could bar any employer it decided was engaged in a "substantial illegal purpose," pointing to conduct like helping break federal immigration law or illegal discrimination. Workers at a disqualified employer would stop earning qualifying payments after the determination. The rule was set to start on July 1, 2026.
November 3-4, 2025: Lawsuits filed
Three challenges followed almost immediately: one from nonprofits, unions and cities; one from the human rights group RFK Human Rights; and one from a coalition of state attorneys general, filed in Massachusetts federal court on November 3. The states amended their complaint on February 10, 2026.
June 3, 2026: Hearing in the states' case
The Massachusetts court heard arguments on the states' motion for summary judgment, according to Oregon's Department of Justice litigation tracker.
June 30, 2026: Rule vacated
Courts struck the rule down a day before it was due to take effect. Judge Myong J. Joun held that the rule violated federal law and the First Amendment, exceeded the department's powers and was arbitrary and capricious.
July 1, 2026: Effective date passes
The original start date came and went with no rule in force. PSLF continued under its existing employer rules.
August 27, 2026: Government appeals
The Justice Department appealed all three rulings, two in the First Circuit and one in the D.C. Circuit.
October 21, 2026: Two appeals dropped
Joint stipulations dismissed the appeals in National Council of Nonprofits v. McMahon and in the RFK Human Rights case. No reason was given.
October 22, 2026: Final appeal dropped
Federal lawyers abandoned the states' appeal as well, per Oregon's tracker and California's attorney general. With that, the June rulings stand and the rule is gone.
What comes next
For now, nothing further is pending on this rule. The administration has not announced a replacement. Separate PSLF issues, including payment-counting delays, continue.
Frequently asked questions
When was the PSLF employer rule finalized?
The Education Department published the final rule on October 31, 2025. It was scheduled to take effect on July 1, 2026.
Did the PSLF employer rule ever take effect?
No. It was vacated on June 30, 2026, just ahead of its July 1 start.
When did the government drop its appeals?
October 21 saw two appeals dismissed; the multistate appeal followed on October 22.
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