How long until income-driven forgiveness?

The three clocks

What counts toward IBR forgiveness

The regulation lists the months that give credit toward IBR's 240 or 300 payments (34 CFR 685.209(k)(4)). A payment under any income-driven plan except RAP counts, as does a month with a $0 payment obligation. For IBR specifically, payments made on or before June 30, 2028 under PAYE or ICR count. A payment under the 10-year standard plan, or under any plan with a payment at least equal to it, counts. So do months in a list of deferments and forbearances: cancer treatment, rehabilitation training, unemployment, economic hardship including Peace Corps service, military service, post-active-duty student deferment, and, from July 1, 2024, national service, National Guard, Defense Department repayment and certain administrative and bankruptcy forbearances. Payments counted for PSLF count too. When loans are consolidated, a weighted average of the qualifying payments on the loans repaid carries over, rounded up to the nearest month.

What counts toward RAP's 360

RAP has its own list (34 CFR 685.209(k)(8)). It includes on-time RAP payments; on-time Tiered Standard payments; any other plan's payment of at least the 10-year standard amount; IBR payments of at least the required amount, minimum included; before July 1, 2028, payments under an income-contingent plan or an alternative plan of at least the required amount; months in an unemployment or economic hardship deferment; and months that ended before July 1, 2026 in the same deferments and forbearances listed for IBR. To be forgiven, a borrower must have used RAP at some point and made the final payment before cancellation under RAP. A borrower who spends 25 years on IBR and then moves to RAP for the last five years meets that condition.

What does not count

The lists are long, but several common situations stay off them. Ordinary discretionary forbearance, the kind a servicer grants for a few months of hardship, does not count unless the borrower later buys the months back where that is allowed. In-school deferment never counts. Months in default count toward IBR only through payments actually made under IBR in default or amounts collected by garnishment or offset, within limits. A late RAP payment loses that month's qualifying status for RAP. And a payment below the required amount on a fixed plan does not count unless the plan's payment is at least the 10-year standard amount. Borrowers who are unsure about a period should look it up in their payment history before assuming it counted.

Buying back months

For PAYE, ICR and IBR, a borrower can obtain credit for months spent in a deferment or forbearance not on the list, other than in-school deferment, by making an additional payment equal to or greater than the current income-driven payment, including a payment of $0, for periods after July 1, 2024 that ended within the last three years. The Department tells the borrower, on request, which months can be bought back this way. This route matters for borrowers who spent months in a general forbearance while their income was low enough that the income-driven payment would have been small.

Choosing a clock

A borrower whose loans all predate July 1, 2026 and who first borrowed after June 2014 can be forgiven ten years earlier on IBR than on RAP. That difference has to be weighed against two RAP features: the waiver of unpaid interest, which keeps the balance from growing, and a payment that may be lower in the middle of the income range. It also has to be weighed against tax: since January 1, 2026, the broad federal exclusion for income-driven forgiveness is gone, so an earlier forgiveness may also mean an earlier tax bill. Borrowers in public service have a much shorter clock, 120 payments under PSLF, explained on the PSLF rules page.

Keeping your own record

Counts span decades, servicers change, and loans move between them, sometimes more than once in a repayment career. Download your payment history once a year, note the plan for each period, and keep records of deferments and forbearances with their dates. If you were on SAVE, note the months in the litigation forbearance; the settlement keeps the provisions of the SAVE rule under which certain deferment and forbearance months count. When the count on StudentAid.gov looks low, compare it with your records before asking for a correction. The forgiveness calculator estimates the amount that would be forgiven at the end of each clock, and taxes on forgiveness covers what may follow.

An example across plans

Take a borrower who started repaying in 2016 as a new borrower, spent six years on IBR, three on SAVE including the forbearance months, and moves in 2026. Six years of IBR payments, 72, count for IBR. The SAVE payments, made under an income-driven plan, also count toward IBR, and some forbearance months may count under the SAVE rule provisions the settlement preserved. If the total reaches 108, IBR forgiveness would come after 132 more payments, about eleven years. On RAP the same history would leave 252 more. A borrower in that position who can still use IBR should compare carefully, using the plan comparator for the payments and this count for the dates. The exact count matters: a difference of a dozen credited months moves forgiveness by a year, so it is worth settling disputed periods with the servicer before choosing a plan on the strength of an estimate.