Many federal student loan borrowers believe they have until July 1, 2028 to enroll in legacy income-driven repayment (IDR) plans like PAYE and ICR. Technically, that is still the official transition timeline. However, new regulations include an important restriction that may cause many borrowers to lose access much earlier.

Under the Department of Education’s RISE regulations implementing the 2025 reconciliation law, any borrower who receives a new Direct Loan on or after July 1, 2026 becomes permanently ineligible for PAYE, ICR, and IBR (source). But even for borrowers who do not take out new loans, the practical window to access PAYE and ICR is much earlier: July 1, 2026.

Understanding these rules now is important, especially for borrowers who depend on PAYE or ICR for lower monthly payments or long-term forgiveness programs like PSLF.

What Are PAYE and ICR?

PAYE (Pay As You Earn) and ICR (Income-Contingent Repayment) are federal income-driven repayment plans. They set monthly payments based on income and family size, rather than the total loan balance.

These plans have been especially useful for:

• Borrowers working toward forgiveness programs like PSLF
• Married borrowers who file taxes separately
• Parent PLUS borrowers using consolidation to access IDR plans
• Borrowers who need lower monthly payments

ICR is especially important because it is currently the main IDR option available to most consolidated Parent PLUS loans.

PAYE can also offer lower payments for some borrowers, especially those using Married Filing Separately or those with older loan structures. PAYE is generally only available to borrowers who meet “new borrower” rules requiring that their loans were taken out after October 1, 2007.

Both PAYE and ICR are scheduled to phase out by 2028. However, under the RISE regulations, access before that date is no longer open-ended. Eligibility now depends heavily on borrower status before July 1, 2026.

The Key Regulatory Changes Most Borrowers Are Missing

The RISE regulations include two important rules that sharply limit enrollment in PAYE and ICR.

Starting July 1, 2026:

• PAYE is limited to borrowers who meet legacy “new borrower” rules and were already enrolled in PAYE as of July 1, 2024.
• ICR is also limited to borrowers who were already enrolled in ICR as of July 1, 2024, with a narrow exception for certain consolidated Parent PLUS borrowers.
• Borrowers who leave PAYE or ICR after the regulations take effect cannot re-enter.

Taken together, these rules mean something important:

To stay in or enter PAYE or ICR under the new system, borrowers generally must already be in those plans before July 1, 2026.

After that point, new enrollment becomes extremely limited and is only available in narrow, grandfathered situations.

There is one more critical rule. Any borrower who receives a new Direct Loan on or after July 1, 2026 becomes ineligible for PAYE, ICR, and IBR. This applies even if their loans previously qualified. It is not a temporary condition, but a permanent eligibility restriction under the new framework. You can read more about this change here.

The Important Exception for Parent PLUS Borrowers

There is one key exception in the rules that applies to certain Parent PLUS borrowers.

Borrowers who consolidate Parent PLUS loans into a Direct Consolidation Loan may still access ICR through June 30, 2028, if they meet specific conditions.

However, this exception only applies if the consolidation completes before July 1, 2026. If a borrower receives any new Direct Loan after that date, their Parent PLUS loans will lose eligibility for ICR under this pathway.

This makes timing especially important for Parent PLUS borrowers who are planning consolidation as part of a repayment or forgiveness strategy. You can read more about these special considerations for Parent PLUS borrowers in our blog.

Why This Matters for Long-Term Repayment Strategy

For many borrowers, the key issue is not whether PAYE and ICR exist, but whether they will still be able to enter them when needed.

Once borrowers fall outside these entry windows, they may have far fewer repayment options later on.

This is especially important for borrowers who are:

• Planning major life changes such as marriage or income shifts
• Relying on low or $0 IDR payments
• Working toward PSLF or long-term forgiveness strategies

PAYE and ICR have provided important flexibility for many borrowers. That flexibility may not be available in the same way in the future.

What Borrowers Should Do Now

Borrowers who think PAYE or ICR may matter for their long-term plan should take time to:

• Review their current repayment plan
• Check whether they are already enrolled in PAYE or ICR
• Consider whether consolidation is needed (especially for Parent PLUS borrowers)
• Make sure their repayment strategy still supports forgiveness goals

If you are unsure where you stand, a full review of your loans and repayment options can help clarify whether action is needed before July 1, 2026.

Final Thoughts

The most important change under the RISE regulations is not that PAYE and ICR are going away in the near future. It is that access to enter these plans is becoming much more limited.

For many borrowers, July 1, 2026 is the practical cutoff for getting into these repayment options under current rules.

Knowing where you stand now can help you avoid losing access to repayment tools that may be important for your financial future and forgiveness strategy.