The One Big Beautiful Bill Act (OBBBA) and Student Loans: What You Need to Know

July 2026

<p>The One Big Beautiful Bill Act (OBBBA) and Student Loans: What You Need to Know</p>

The OBBBA introduces sweeping reforms to, among other things, the federal student loan system, which are set to take effect starting July 1, 2026. The law, signed on July 4, 2025, introduces new repayment plans, adjusts borrowing limits, and redefines eligibility for forgiveness through Income-Driven Repayment (IDR) programs. Understanding these changes is critical for making informed financial decisions.

Key repayment plan changes

OBBBA introduces two new repayment plans starting on July 1, 2026 — the Tiered Standard Repayment Plan and the Repayment Assistance Plan (RAP) — and phases out existing IDR plans.

Plan NameMonthly PaymentsRepayment PeriodEligible Loan TypesDetails
Standard Plan

Based on the borrower’s loan balance and interest rates.

Amount calculated, would be fixed.

Lowest minimum payment $50.

Loans will be paid off (principal and interest) by the end of the repayment period.

Loans that aren’t consolidated, up to 10 years.

Loans that are consolidated, up to 30 years.

Any Direct, FFEL Program Loans, Parent PLUS Loans, and Consolidated Loans.

Available only if borrower has no loans disbursed on/after July 1, 2026.

Graduated Plan

Based on the borrower’s loan balance and interest rates.

Payment will start out low and increase every 2 years.

Payment will never be less than the amount of interest that will accrue between payments.

Payment won’t be more than 3 times greater than any other plans.

Loans will be paid off (principal and interest) by the end of the repayment period.

Loans that aren’t consolidated, up to 10 years.

Loans that are consolidated, up to 30 years.

Any Direct, FFEL Program Loans, Parent PLUS Loans, and Consolidated Loans.

Available only if borrower has no loans disbursed on/after July 1, 2026.

Extended Plans

Based on the borrower’s loan balance and interest rates.

Amount calculation will either be fixed or graduated.

Generally lower payments compared to the Standard or Graduated plans.

Loans will be paid off (principal and interest) by the end of the repayment period.

Up to 25 years.

Any Direct Loans with no outstanding balance on/after October 7, 1998. Must have more than $30,000 in outstanding Direct Loans.

Any FFEL Program Loans with no outstanding balance on/after October 7, 1998. Must have more than $30,000 in FFEL Program Loans.

Available only if borrower has no loans disbursed on/after July 1, 2026.

Tiered Standard Repayment Plan

Based on the borrower’s loan balance and interest rates. The loan balance will determine the repayment term and monthly payment.

Loans will be paid off (principal and interest) by the end of the repayment period.

  • 10 years for balances of $25,000 or less
  • 15 years for balances of $25,000–$49,999
  • 20 years for balances of $50,000–$99,999
  • 25 years for balances of $100,000 or more

Any Direct Loans, Parent PLUS, or Direct Consolidated loans, including repaying Parent PLUS loans and repaying Direct consolidated loan that paid off a Parent PLUS loan (double consolidation).

Available to borrowers with at least 1 loan disbursed on/after July 1, 2026, that has entered repayment.

Repayment Assistance Plan (RAP)

Based on a percentage of the borrower’s adjusted gross income divided by 12.

Based on a percentage of the borrower’s and spouse’s adjusted gross income (filing jointly) divided by 12.

If spouse, filling jointly only, has eligible federal student loans, will be taken into account and could potentially reduce the monthly payment.

$50 will be deducted from monthly payment for any dependent listed on the borrower’s federal tax return.

Lowest minimum monthly payment of $10.

Interest subsidy applied to subsidized and unsubsidized Direct Loans, for on-time payments during periods of repayment.

Matching principal payment up to $50 for on-time payments during periods of repayment.

30 years

Any Direct Loans, or Direct Consolidated loans, that did not include repaying Parent PLUS loans and repaying Direct consolidated loan that paid off a Parent PLUS loan (double consolidation).

Available to borrowers regardless of loan disbursement date.

Income-Based Repayment (IBR)

10–15% of your discretionary income (and your spouse’s if filing jointly). Never more than federal 10-year Standard Repayment Plan amount.

Interest subsidy applied to subsidized loans only for the first 3 years. March 2027 or after, payments must be on-time and in repayment to receive interest subsidy.

  • 25 years for loans taken out before July 1, 2014
  • 20 years for loans taken out after July 1, 2014

Any Direct, FFEL Program Loans, and Consolidated Loans.

Available only if borrower has no loans disbursed on/after July 1, 2026.

Consolidated Parent PLUS Loans disbursed prior to July 1, 2026, will be eligible for IBR in the future. Borrowers must make at least 1 payment on ICR prior to moving to IBR.

There is no partial financial hardship requirement under the revised IBR plan. Historically, IBR required a partial financial hardship for eligibility.

Income-Contingent Repayment (ICR)

The lesser of the following:

  • 20% of your discretionary income, or
  • What you would pay on a repayment plan with a fixed payment over the course of 12 years, adjusted according to your income.

25 years

Any Direct or Direct Consolidated loans including repaying Parent PLUS loans.

Available only if borrower has no loans disbursed on/after July 1, 2026.

Only available until June 30, 2028.

Only option for Consolidated Parent PLUS borrowers before IBR eligibility. Borrowers must make at least 1 payment on ICR prior to moving to IBR.

Pay As You Earn (PAYE)

10% of your discretionary income (and your spouse’s if filing jointly).

Never more than federal 10-year Standard Repayment Plan amount.

FSA updating systems to apply interest subsidy to eligible loans. Please note, there will be more information to come.

20 years

Any Direct or Direct Consolidated loans that did not repay Parent PLUS loans.

Available only if borrower has no loans disbursed on/after July 1, 2026.

Only available until June 30, 2028.

Forgiveness and eligibility updates

  • Medical and dental residency/fellowship. The OBBBA was updated to allow payments made during medical or dental residencies and fellowships – assuming the employer is an eligible nonprofit or public service hospital – to count towards Public Service Loan Forgiveness.1
  • Eligible Plans for PSLF. The OBBBA was updated to include the Repayment Assistance Plan (RAP) as an eligible repayment plan for PSLF when making on-time payments.

Undergraduate borrowing limits

Limits on New Loan Originations by School YearDependent StudentIndependent StudentSubsidized Limit from Overall Amount
Undergraduate Year 1$5,500$9,500$3,500
Undergraduate Year 2$6,500$10,500$4,500
Undergraduate Year 3+$7,500$12,500$5,500

New borrowing limits effective July 1, 2026

  • Undergraduate limits are not changing.
  • Lifetime federal student loan limit is $257,500, regardless of amounts paid or discharged (excludes Parent PLUS).
  • Graduate and Professional PLUS Loans will no longer be available for new students. A graduate and/or professional student who is eligible for the 3-year interim exception could receive a Graduate and Professional Loan during that interim exception.
  • Students currently enrolled have a 3-year interim period to complete their program. The new limits will start to be enforced starting in the 2029 – 2030 academic year (July 1, 2029 – June 30, 2030), but the new limits could be enforced sooner if student takes an action that will cancel the exception.
  • Students that qualify for the interim exception will not be able to opt-out. 
Borrower TypeAnnual Limit (per year)Limit Cap
Graduate$20,500$100,000
Professional$50,000$200,000
Parent (per student)$20,000$65,000

Deferment, default, and rehabilitation

  • Deferment: Economic hardship and unemployment deferments end (in effect July 1, 2027).
  • Forbearance: Available in 9-month increments, up to 24 months total (in effect July 1, 2027).
  • Default: Loans can be rehabilitated twice with $10 minimum payments (in effect July 1, 2027). Consolidating out of default will be subject to the Tiered Standard and RAP plans.

Frequently Asked Questions

The percentage of what will be used for the adjusted gross income will increase every $10,000. It will range from 1% to 10%. The breakdown is below.

  • 1% of adjusted gross income: more than $10,000 and up to $20,000
  • 2% of adjusted gross income: more than $20,000 and up to $30,000
  • 3% of adjusted gross income: more than $30,000 and up to $40,000
  • 4% of adjusted gross income: more than $40,000 and up to $50,000
  • 5% of adjusted gross income: more than $50,000 and up to $60,000
  • 6% of adjusted gross income: more than $60,000 and up to $70,000
  • 7% of adjusted gross income: more than $70,000 and up to $80,000
  • 8% of adjusted gross income: more than $80,000 and up to $90,000
  • 9% of adjusted gross income: more than $90,000 and up to $100,000
  • 10% of adjusted gross income: more than $100,000

The monthly payment would automatically be $10 a month, which over 12 months would be $120. Please note that the monthly payment will never be less than $10 a month.

The dependents listed on the borrower’s tax return will impact the monthly payment. As $50 is deducted, this could cause the borrower to still have a $10 monthly payment. Please note that the monthly payment will never be less than $10 a month.

If the full, on-time monthly payment is less than the interest that has accrued between the previous due date and the current due date, then the unpaid interest for that month will be subsidized. The interest subsidy will only be applied after the borrower has entered the RAP plan, so any interest accruing prior to RAP will not be subsidized. If the borrower has any periods that are in a nonrepayment status, the interest that accrues during that time will not be subsidized.

If the full, on-time monthly payment does not reduce the principal balance by at least $50, then a matching principal payment up to $50 will be made to make sure the principal balance is decreasing. The matching principal payment will not exceed $50 if eligible.

Federal Student Aid (FSA) will be releasing more information on how the interest subsidy and matching principal payment will work. Please note that there is no set time frame for this information to be available. Please review studentaid.gov for more information.

Yes, if the borrower’s on-time monthly payment is less than $50, they will receive a matching principal payment of what they paid, but not more than what they actually paid. The government will review if the monthly payment is $50 or less than the amount that was paid.

If a borrower decides to leave IBR, ICR, or PAYE and move to the RAP plan, those months will still count towards the overall forgiveness. If the borrower decides to leave RAP and move to IBR, ICR, or PAYE, then that time on RAP will not count towards the overall forgiveness. Examples listed below:

  • Borrower 1 has 5 years of qualifying payments on IBR, and they decide to move to RAP. Those 5 years on IBR will count towards the 30 years required for RAP.
  • Borrower 2 has 5 years of qualifying payments on RAP, and they decide to move to IBR. Those 5 years on RAP will not count towards the 20-25 years required for IBR.

If the monthly payment amount while on RAP is greater than or equal to the 10-year Standard Repayment Plan, then those monthly payments can count towards IBR, ICR, and PAYE forgiveness plans.

There are certain loan types, like FFEL Program Loans, that will not be eligible for the Tiered Standard Plan and the Repayment Assistance Plan (RAP). If the borrower has a mix of loans that are ineligible for the new plans and have loans that are eligible for the new plans, then the eligible Direct Loans would be placed on either of the 2 new repayment plans and the non-Direct Loans would be placed on one of the existing plans that the loans are eligible for.  Examples below:

  • Borrower 1 has FFEL Program loans disbursed 02/02/2003 on the Graduated Plan and the Direct Loans disbursed 10/4/2026 on the Repayment Assistance Plan (RAP).
  • Borrower 2 has Direct Parent Plus loans disbursed 10/3/2016 on the Extended Plan, and the Direct Consolidated Loans disbursed 04/05/2024 on Income Based Repayment (IBR) plan. 
  • Borrower 3 has Direct Plus loans disbursed 09/16/2027 on Tiered Standard, and the Direct Subsidized Loans disbursed 05/29/2025 on Repayment Assistance Plan (RAP).
  • Borrower 4 has a Direct Consolidated loan, didn’t pay off Parent PLUS loans, disbursed 5/1/2023 on RAP and Direct Parent PLUS loan disbursed 3/15/2028 on Tiered Standard.
  • Borrower 5 has a Direct PLUS Graduate loan disbursed 5/4/2020 on the PAYE Plan, and a Direct Subsidized loan disbursed 8/4/2026 that is still in an in-school status.

Yes, the institution may set a loan limit that is lower than the maximum amount allowed by law. The same limit will be applied for all borrowers in the same program of study.

If the student is less than full time, they will not be able to borrow the maximum amount of federal student loans. For more information regarding enrollment status impacting educational funds, please contact the Financial Aid Office of the respective school. Examples of enrollment statuses are below:

  • Enrolled Full Time
  • Enrolled Half Time
  • Enrolled Less Than Half Time

An independent student is one of the following but not limited to: 

  • At least 24 years old
  • Married
  • Veteran
  • Orphan
  • An Emancipated Minor

A dependent student is someone who does not fall under the independent student criteria. 

For a student or a Parent PLUS borrower to qualify for the 3-year student loan interim exception, they need to meet the below requirements:

  • Must be enrolled in a program of study at an institution as of June 30, 2026.
  • Received at least one Direct Loan or Direct Parent PLUS loan for that program of study before July 1, 2026.
  • Enrolled at the same institution and are seeking the same credential (associates, bachelors, graduate, professional) after July 1, 2026, and have not stopped being enrolled at the same institution at any point on/after July 1, 2026.
    • Approved leave of absence is not considered a break in enrollment.
  • A student cannot change their credential level and maintain eligibility for the exception.
    • Changing majors within the credential level is allowed.

If the student attends a school that has now closed and the student transfers to another school that does have an arrangement with the closed school (teach-out agreement), then the student will continue to qualify for the interim exception.

Yes, if the student originally qualifies for the interim exception while at the school that is merging with another school, they will still qualify for the interim exception.

Yes, if the student is enrolled in a program of study that will guarantee admission into another degree program, program of study, or working towards multiple degrees at the same time, then the student will not qualify for the interim exception.

These programs are often referred to as:

  • Dual Degree Programs
  • Joint Degree Programs
  • Concurrent Degree Programs
  • Double Degree Programs
  • Combined Degree Programs

Please note, if the student is questioning if their special program qualifies for the interim exception or not, they should contact the Financial Aid Office at their school.

Some examples include but are not limited to the following:

  • Borrower is pursuing both a Master of Business Administration (MBA) along with a Juris Doctor (JD) degree.
  • Borrower is pursuing a Doctor of Pharmacy (PharmD) degree while first enrolling in a Bachelor of Pharmacy (B.Pharm) program.
  • Borrower is pursuing both a Master of Social Work (MSW) and a Master of Public Health (MPH)

No, if the student is a part of a school where they are attending one school that has an articulation agreement with another school and they transfer to that second school, they will lose eligibility for the interim exception.

An articulation agreement is when two schools have a formal agreement that will outline how the academic credits that are earned at one school will transfer and apply to the second school for another degree.

Explore your options with an expert guide

Have questions about how the OBBBA might affect your current or future student loans? Our student loan specialists can help you. Schedule a free 30-minute consultation2 to get started, learn more here.

All credit products are subject to credit approval.

This information is provided for informational purposes only and is not intended to constitute professional financial, legal, accounting, or tax advice. KeyBank is a private national banking association and is not affiliated with, endorsed by, or acting on behalf of the United States Department of Education. We do not guarantee outcomes, estimates, availability, or timeframes. We offer an optional, complimentary service to clients who seek assistance in exploring student loan funding options.

1

To qualify for Public Service Loan Forgiveness (PSLF), you must be employed by a U.S. federal, state, local, or tribal government or not-for-profit organization (federal service includes U.S. military service); work full-time for that agency or organization; have Direct Loans (or consolidate other federal student loans into a Direct Loan); repay your loans under an Income-Driven Repayment plan; and make 120 qualifying payments. For full program requirements, visit: studentaid.gov/manage-loans/forgiveness-cancellation/public-service.

2

The student loan consulting services are an optional and free service, and do not constitute legal, tax, investment, accounting or other professional advice. For full details, please refer to the KeyBank Student Loan Consulting Services Terms & Conditions.

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