SAVE Plan Borrowers: Your Options Before the July 2028 Deadline, Including If You Live in the UK
Borrowers with US federal Direct Loans in SAVE (REPAYE), PAYE or ICR have until 1 July 2028 to elect a replacement: the Repayment Assistance Plan (RAP), Income-Based Repayment (IBR), or a standard, graduated or extended plan. Without a choice, loans eligible for RAP go into RAP and the rest into IBR on 1 July 2028. Living in the UK does not change the deadline, but it does change how your income is documented.
Why SAVE borrowers have to move
34 CFR 685.209 lists five income-driven plans and states that REPAYE may also be referred to as SAVE. The final rule of 1 May 2026, which implements Public Law 119-21 (the Working Families Tax Cuts Act), sets out the background: SAVE/REPAYE was enjoined in its entirety by the 8th Circuit on 18 February 2025, the SAVE Plan Final Rule was later vacated in full in Missouri v. Trump, and REPAYE/SAVE borrowers were placed in forbearance in August 2024. The Act itself directs the Secretary to ensure that borrowers in income-contingent plans, REPAYE (SAVE) included, select a new plan before 1 July 2028.
Until then the regulation keeps REPAYE, PAYE and ICR open only to borrowers who have not received a Direct Loan on or after 1 July 2026. Anyone who borrows again, for instance for a further degree, loses those plans, and their new loans can only be repaid under the Tiered Standard plan or RAP (34 CFR 685.210).
The options, compared
Plans available to SAVE, PAYE and ICR borrowers before 1 July 2028
| Plan | Monthly payment | Forgiveness |
|---|---|---|
| Repayment Assistance Plan | AGI-based base payment / 12, minus $50 per dependent; minimum $10 | After 360 qualifying payments over at least 30 years |
| IBR, new borrower | Lesser of 10% of income above 150% of the poverty guideline / 12, or the 10-year standard payment | After 240 payments over at least 20 years |
| IBR, other borrowers | Lesser of 15% of income above 150% of the poverty guideline / 12, or the 10-year standard payment | After 300 payments over at least 25 years |
| Standard, graduated or extended | Set by the plan terms (34 CFR 685.208, not covered in detail here) | Not income-driven |
IBR has two exclusions worth checking first: it applies only to Direct Loans made before 1 July 2026, and a borrower who has made 60 or more qualifying REPAYE payments on or after 1 July 2024 may not enrol in it. The final rule also confirms that payments under SAVE/REPAYE, and months in the litigation forbearance from August 2024, do not count towards IBR forgiveness.
Working out a RAP payment
The base payment bands in 34 CFR 685.209(b)(2) are: $120 if AGI is $10,000 or less; 1% of AGI between $10,000 and $20,000; then one extra percentage point for each further $10,000 band, reaching 9% between $90,000 and $100,000; and 10% above $100,000. Divide by 12, subtract $50 for each dependent, and apply the $10 floor.
- AGI $62,000, no dependents: 6% band, $62,000 x 6% = $3,720; $3,720 / 12 = $310 a month.
- AGI $62,000, one dependent: $310 minus $50 = $260 a month.
- AGI $9,000: base payment $120; $120 / 12 = $10 a month.
For RAP, a dependent is someone who qualifies under section 152 of the Internal Revenue Code and was claimed on the borrower's federal income tax return. On-time payments trigger two subsidies: unpaid interest for that month is not charged, and if principal falls by less than $50 the Department makes up the difference, up to the lesser of $50 or the payment made. Paying in advance moves the due date forward and can cancel these benefits unless you opt out of advancing it.
If you live in the UK
The repayment regulation contains several rules that matter to borrowers outside the United States:
- Income means AGI as reported to the IRS or, alternatively, an amount calculated from documentation of all forms of taxable income provided to the Secretary.
- Poverty guideline: a borrower who is not resident in a State identified in the federal poverty guidelines uses the guideline for the 48 contiguous States, for the relevant family size. This matters for IBR, whose formula is based on income above 150% of that guideline.
- No IRS data available: if the Department has approval but cannot obtain tax information from the IRS, the borrower must document income and family size (IBR) or income and number of dependents (RAP).
- Married borrowers: for RAP, IBR, PAYE and REPAYE, a borrower who files separately is assessed on their own income only; joint filers are assessed on combined income, unless they certify separation or that they cannot reasonably access the spouse's income.
- Change in circumstances: a borrower whose income has fallen since the last return can ask for a recalculation with alternative documentation; the Department grants a forbearance while it recalculates.
Outside the scope of these sources
How UK earnings or UK tax returns are treated for US tax purposes is not covered by the documents in this base. The regulation speaks only of AGI reported to the IRS or alternative documentation of taxable income; ask your loan servicer which documents it accepts.
Public Service Loan Forgiveness and Parent PLUS
Under 34 CFR 685.219, qualifying repayment plans for PSLF include any income-driven plan, the Repayment Assistance Plan, and an income-contingent plan for payments received on or before 30 June 2028. Moving from SAVE to RAP or IBR therefore preserves a PSLF route, subject to the programme's other conditions, including 120 qualifying payments while working for a qualifying employer.
Parent PLUS loans, and consolidations that repaid them, cannot go into RAP. The final rule explains that Parent PLUS loans consolidated before 1 July 2026, with at least one IDR payment made by 1 July 2028, are moved to IBR and keep PSLF eligibility; a parent who takes out any new Direct Loan from 1 July 2026 must repay their Parent PLUS loans under Tiered Standard, which does not qualify for PSLF.
Before you decide
- List each loan, its plan and whether it is a Parent PLUS or consolidation.
- Confirm you have not received a Direct Loan since 1 July 2026; if you have, the old plans are already closed to you.
- Count qualifying REPAYE payments since 1 July 2024 if IBR is on your shortlist.
- Estimate RAP using your AGI and the dependents on your federal return.
- Prepare income documentation if the IRS has no usable return for you.
- Make your election before 1 July 2028; you may start the new plan earlier if you wish.
How the forgiveness clock compares
Time to forgiveness is often what SAVE borrowers notice first. Under the REPAYE terms still written into 34 CFR 685.209(k), forgiveness came after 240 payments over 20 years for undergraduate-only loans, 300 payments over 25 years if any loan was for graduate study, and as early as 120 payments for an original balance of $12,000 or less, plus 12 payments for each additional $1,000. RAP requires 360 qualifying payments over at least 30 years. Commenters asked the Department to shorten that period; it replied that the 30-year term is set by statute (HEA section 455(q)) and declined. In exchange, RAP's interest and principal subsidies are designed to stop balances growing when on-time payments are made.
To check a specific point against the regulation, you can ask the Kopik base on US federal student aid, for example how a borrower with an AGI of $8,000 is treated under RAP. Each answer quotes 34 CFR or the final rule.
Test your repayment scenario
Ask the FAFSA and federal loans base about RAP, IBR, PSLF or the 2028 transition, with citations to the official text.
Sources: 34 CFR 685.209, 34 CFR 685.219 (eCFR current to 1 October 2026) and the final rule of 1 May 2026. General information only, not financial advice.
Frequently asked questions
What happens to SAVE plan borrowers in 2028?
Before 1 July 2028 they must elect RAP, IBR, or a standard, graduated or extended plan. Those who do not choose are placed in RAP for eligible loans and IBR for the others on 1 July 2028.
Can I switch from REPAYE (SAVE) to RAP now?
Yes. Any Direct Loan borrower with eligible loans may repay under RAP, and the regulation lets borrowers start their elected plan earlier than 1 July 2028. Parent PLUS loans and consolidations that repaid them are not eligible for RAP.
Which poverty guideline applies if I live in the UK?
34 CFR 685.209 states that a borrower who is not resident in a State identified in the federal poverty guidelines uses the guideline for the 48 contiguous States for the relevant family size.
Do I keep my PSLF progress if I leave SAVE?
RAP and IBR are qualifying plans for PSLF under 34 CFR 685.219. Payments under an income-contingent plan count if received on or before 30 June 2028. All other PSLF conditions still apply.
What is the minimum RAP payment?
$10 a month. The base payment for an AGI of $10,000 or less is $120 a year, which divided by 12 gives $10, and any calculated payment below $10 is raised to $10.
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