If You're Chasing PSLF, File the Employment Certification This Week.

If you’re on Public Service Loan Forgiveness and you haven’t filed an Employment Certification Form this year, file one this week. A new rule that took effect July 1, 2026 lets the Education Department disqualify your employer from PSLF for what it calls “substantial illegal purpose” activity. Every month you worked before that kind of disqualification stays counted. Every month after, you’re on your own.

The Department published the final rule on October 31, 2025, and it landed on July 1. It adds a new way for an employer to lose “qualifying employer” status. The Department’s stated examples are aiding illegal immigration and supporting terrorism. Its own estimate is that fewer than ten employers per year will actually get disqualified.

Small number. The problem is you don’t get told your organization is on the list until it is.

On June 19, the Department revised the Employment Certification Form itself. Effective July 1, the employer you ask to sign it must attest, under penalty of perjury, that it has not engaged in “substantial illegal purpose” activity on or after that date. That is a big ask on a lot of HR desks. Some employers will take longer to sign. Some may refuse until legal review. The Commonwealth of Massachusetts, in a challenge to the rule, warned the vague phrasing could sweep in nonprofits doing “support for immigrants, gender affirming care, diversity, equity and inclusion initiatives, and political protest.” Whether that argument wins in court is above our pay grade. What you can do about it below is not.

Here’s the mechanic that matters. Months you worked at a qualifying employer, that have been certified, count toward your 120 payments even if the Department later disqualifies that employer. Only months after the disqualification stop counting. So the certified months are locked in. The uncertified months are the ones exposed.

For a borrower five years into a ten-year PSLF march, that’s roughly sixty months of payments at risk if the paperwork isn’t done. On a $60,000 loan balance, that is the difference between $0 forgiven and everything forgiven.

Do this now, in this order.

Log into StudentAid.gov and pull an Employment Certification Form. File one covering every month you have worked at your current employer through today. If you have never filed one, file it once. If you filed one last year, file another. There is no cost, no cap, no penalty for filing again.

If you were on SAVE, note that the plan was vacated on March 10, 2026. You should have been notified to switch. RAP is a qualifying PSLF plan and became available July 1. IBR is still an option. Do not sit in forbearance while you decide. Forbearance months don’t count toward PSLF.

If you have already hit 120 qualifying payments, apply for forgiveness now. Do not wait for the annual cycle to come around.

The rule sits in 34 CFR 685.219 for anyone who wants the citation. The revised form’s Federal Register notice went up June 19, 2026. Multiple legal challenges are in progress. As of today, both the rule and the new form are in force.

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