The Revision Is Pending, Not Approved

The most important clarification: as of this writing, the revised PSLF form has not been approved.

When a federal agency changes an information-collection form like the PSLF Employment Certification and Application, it has to clear that change through OMB under the Paperwork Reduction Act. The Education Department submitted this revision as an emergency request — and OMB received it on June 18, 2026. As of late June, the public review record shows no concluded date and no conclusion action, which means the request is still in "Pending Review" status. OMB has not approved it, approved it with changes, or rejected it.

You can track the status yourself. The collection is filed under OMB Control Number 1845-0110, and its review history is publicly viewable on the federal regulatory tracking site:

Check the live status: reginfo.gov — OMB control number 1845-0110 https://www.reginfo.gov/public/do/PRAOMBHistoryByOmbControlNumber?ombControlNumber=1845-0110

If that page eventually shows a concluded date with an approval action, the revised form is moving forward. Until then, treat the change as proposed, not final.

The suddenness of the move — rather than its size — is what triggered concern among borrower advocates. But "sudden" and "final" are not the same thing, and right now the form change is still in the approval pipeline.

Why the Form Is Being Revised: Two Very Different Reasons

The revision bundles together two changes with very different legal profiles. Understanding the distinction explains why the approval may not be straightforward.

Reason 1: Adding the Repayment Assistance Plan (RAP) — routine

A set of federal student loan changes takes effect July 1, 2026, including the arrival of a new income-driven repayment plan called the Repayment Assistance Plan (RAP). RAP qualifies for PSLF, so the certification form has to be updated to reflect it alongside the income-driven plans that already count. This change is uncontroversial. It simply conforms the form to a statute that's already settled law — the One Big Beautiful Bill Act — and reflects which plans feed qualifying payments into PSLF going forward.

For most borrowers, this is the practical headline: RAP is a new qualifying option, and the form needs to list it.

Reason 2: Adding the "substantial illegal purpose" employer attestation — contested

The second change is the one drawing scrutiny. The revised form would add a new certification — signed under penalty of perjury — attesting that the borrower's employer has not engaged in activity with a "substantial illegal purpose" on or after July 1, 2026. This language flows from an executive order and an accompanying final rule the Department issued in late 2025.

That rule is the subject of active litigation. Multiple coalitions — including a group of states, nonprofit organizations, and unions and advocacy groups — have filed suit challenging it. The Department's own estimate is that the provision would disqualify only a small number of employers, but the legal fight over whether the rule is valid is ongoing.

Why the Litigation Could Complicate — or Split — the Approval

Here's where the two reasons interact in a way borrowers should watch.

Because the RAP update is settled and the employer-attestation provision is contested, OMB's review may not be a simple yes-or-no on the whole package. Under its Paperwork Reduction Act authority, OMB can approve a form with changes — meaning it could clear the conforming RAP updates while directing the Department to remove or hold the disputed attestation field.

Functionally, that would split the revision in two: the uncontroversial repayment-plan language could be approved and take effect, while the "substantial illegal purpose" attestation is held back pending the outcome of the court challenges. This isn't a prediction — it's one realistic scenario, and it follows a clear procedural path. An administration that wants the plan updates live by July 1 has reason to let the conforming changes through without waiting on the litigated piece.

The countervailing possibility is that, because the Department filed this as an emergency request specifically to beat the July 1 date, OMB approves the package all at once. It's also worth being precise about scope: OMB's review is formally about paperwork burden and practical utility, not the legality of the underlying rule. OMB is not a court and won't rule on whether the attestation is lawful. But timing and scope decisions can reflect pending litigation, and that's the seam to watch as the review concludes.

The bottom line for borrowers: the part of this revision that matters most to your day-to-day PSLF tracking — the addition of RAP as a qualifying plan — is the part least likely to be held up. The contested attestation is a separate question that may resolve on a different track.

If You Have a Pending PSLF Application

Because the form change overlaps with the broader July 1 transition, it's reasonable to verify your status rather than wait. If you submitted a PSLF or employment-certification form recently, here's a sensible checklist:

1. Check your application status at StudentAid.gov under your PSLF tracker.
2. Confirm the Department received it — keep any confirmation emails or submission receipts.
3. Download a copy of the version you submitted, so you have a record of the fields you completed.
4. Don't preemptively resubmit. If the revised form is approved and adds a required field, your servicer or the Department should notify you. Resubmitting without instruction can create duplicate records.
5. Re-certify your employment if it's been more than a year since your last certification — that's good practice regardless of any form change.

A submission made on the current, valid form does not become worthless because a revision is pending. Form versions transition in an orderly way, and the existing form remains valid while it's the approved version of record.

What This Means Going Forward

PSLF rewards consistency: 120 qualifying payments while working full-time for an eligible employer. The form is the vehicle for certifying that work and those payments — but a pending revision to the form does not change the underlying program, your payment count, or the credit you've already earned.

What to actually do:

• Confirm your loan type. Only federal Direct Loans qualify for PSLF. If you hold other federal loan types, talk to a specialist before consolidating — consolidation can affect existing payment counts, so get advice first.
• Verify your employer qualifies and keep your employment certification current.
• Make sure you're on a PSLF-qualifying repayment plan, and understand that the new Tiered Standard plan does not qualify, while income-driven plans and RAP do.
• Watch the form's approval status at the reginfo.gov link above if you want to know the moment the revision is finalized.

Get Help Modeling Your Situation

The form revision is a paperwork question. The bigger decisions — which repayment plan keeps every payment counting toward forgiveness while keeping your monthly amount manageable — are where the real money is.

Use the Hope Hero portal to confirm your PSLF payment count, verify your loan types and employer eligibility, and model your repayment options using your actual income. If you have a pending application, we can help you confirm it's received and in process. The program is stable; the paperwork is in transition. A little clarity now protects years of qualifying payments.

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Status note: This article reflects the situation as of June 25, 2026. The PSLF form revision (OMB Control Number 1845-0110) was pending OMB review and had not been approved as of that date. Check the reginfo.gov link above for the current status.