On December 31, 2025, a temporary federal tax exemption for forgiven student loan debt expires. Beginning in 2026, borrowers who receive forgiveness through income-driven repayment (IDR) plans may once again face federal and state income tax on any discharged balance.

The exemption, created in 2021, was intended to give long-term borrowers breathing room. Typically, forgiven debt is taxable - meaning that the balance of the forgiven debt was treated like ordinary income and added to your tax return. This could mean large tax bills - something that borrowers who struggled to repay their student loans for 20 or 25 years likely couldn't afford.

The change does not affect Public Service Loan Forgiveness, which remains tax-free. But it will reshape financial planning for millions in IBR, PAYE, and ICR (along with those in other programs that may be taxable).

Milestone Date Matters More Than The Processing Date

A critical rule shapes who owes taxes and who doesn’t by the timeline: The date for federal tax purposes is when the borrower becomes eligible for forgiveness, not when the cancellation is processed.

Servicer backlogs have always meant that loans may take weeks or months to move from “eligible” to “fully discharged.” But for federal taxes, the moment the borrower hits the required number of qualifying payments (typically 240 or 300) is the moment that determines the tax year.

Example

• A borrower’s 240th qualifying payment posts on December 15, 2025.
• Their loan servicer completes the discharge on January 20, 2026.
• For federal tax purposes, the borrower is treated as having been forgiven in 2025, the final year of tax-free IDR cancellation.

If that same milestone is reached on January 2, 2026, the forgiven balance would fall into the first year of renewed tax liability.

For borrowers close to the finish line, a few weeks’ difference could translate to thousands of dollars in taxes.

Who Is Most At Risk of A "Tax Bomb"?

There are a few groups that need to especially be paying attention.

Borrowers Approaching 20 or 25 Years of IDR Payments

Those nearing the end of IBR, PAYE, or ICR repayment terms face the highest stakes. Borrowers who began repayment in the late 1990s or early 2000s (especially those with long periods of deferment or forbearance) may unexpectedly find themselves close to forgiveness without realizing it.

This group should confirm their IDR payment count as soon as possible. Some borrowers received payment adjustments in recent years that shortened their remaining timeline, pushing them closer to loan forgiveness without warning.

Borrowers With High Balances

Large remaining balances create the largest tax exposure. Even modest incomes can face significant tax bills when tens of thousands of dollars become taxable at once.

Borrowers with graduate school debt, Parent PLUS loans consolidated into IDR plans, or loans that have grown due to interest are most likely to feel the impact.

Run the Tax Bomb Calculator to get an estimate of what you could owe.

Borrowers in States That Tax Forgiven Debt

Several states treat forgiven student debt as taxable income. After 2025, the list will grow as 20 states automatically conform their tax rules to federal law - meaning when the tax-free forgiveness expires, the same thing happens in those states. Borrowers living in these states should pay especially close attention.

Some SAVE Borrowers Stuck in Legal Forbearance

Millions enrolled in SAVE are currently in a forbearance due to ongoing litigation. This period does not count toward IDR forgiveness or PSLF progress.

For borrowers who may already have reached or be near their 20- or 25-year thresholds, this pause creates a risk. Borrowers who have the time need to switch into IBR, ICR, or PAYE before December 31 to ensure their forgiveness is completed.

How Borrowers Can Prepare Now

There are things that student loan borrowers can do now.

1. Confirm Your Payment Count

Contact your loan servicer and request your updated IDR qualifying payment total. It's important since the IDR tracker disappeared from StudentAid.gov. Servicers can take time to respond, and borrowers close to the 20- or 25-year mark should act soon.

2. Document the Date You Reach Eligibility

Keep screenshots, statements, and written confirmation showing the date your qualifying payment threshold is met. This date determines whether forgiveness is tax-free.

3. Consider Switching Repayment Plans if You’re in SAVE

Borrowers stuck in the SAVE forbearance who believe they are nearing forgiveness should evaluate whether moving to IBR, ICR, or PAYE before December 31, 2025 will ensure they qualify.

4. Review Potential Tax Liability

Borrowers likely to reach forgiveness after 2025 should run The College Investor Tax Bomb Estimator to see:

• projected taxable income
• estimated federal and state tax liability
• whether the IRS “insolvency” exception might apply

A tax professional can help outline possible outcomes.

5. Monitor Federal and State Policy

Congress could extend the exemption, but no extension has passed. States may also update their treatment of forgiven debt. Borrowers should stay alert to policy changes that could affect their 2026 tax bill.

What To Do Now

The end of tax-free IDR forgiveness means that more complications may come from time-based student loan forgiveness. For those who have been repaying loans for decades, the next month may determine whether long-awaited forgiveness arrives without a financial sting or whether the forgiven balance creates a tax burden.

Use this time now to understand payment counts, evaluate tax liability, and ensure you know when to expect your forgiveness milestone to be reached.

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