Who Must Switch to RAP (And Who Doesn't)

The 2025 law splits the borrower universe along two lines: what plan you're on now, and when your loans were made. Cross-reference yourself below.

MUST switch (deadline running)

SAVE borrowers — ~7.5 million people

The plan is terminated; staying is not an option. Your servicer notice (July 1–Aug 15, 2026) starts a 90-day clock, your menu is RAP / IBR / Tiered Standard, and if you do nothing you get placed. Full playbook: the SAVE exit guide.

PAYE and ICR borrowers

Both plans are being phased out under the same law. You are not under the SAVE court order's 90-day gun, but you are on the July 1, 2028 clock: choose RAP, IBR, or Tiered Standard by then, or the Department moves you. Two years sounds generous; the strategic reasons to move early (or deliberately late) are on Switch Now or Wait.

MAY switch (genuine choice)

IBR borrowers

IBR is the one legacy income-driven plan Congress kept. If you're on it with pre-July-2026 loans, you can stay indefinitely, keep your 20- or 25-year forgiveness clock, and ignore RAP entirely — often the right call if you're deep into your clock. RAP tempts when its payment is meaningfully lower or when balance growth is eating you alive; the head-to-head is at RAP vs IBR.

Standard, Graduated, and Extended plan borrowers

Fixed-payment borrowers with pre-2026 loans can keep their current schedule. RAP is an option if income-driven payments or eventual forgiveness would serve you better — run the calculator and compare against what you pay now.

Defaulted borrowers

You can't enroll in anything until the default is cured — but with collections, offsets, and garnishment fully switched back on, curing it and landing in RAP or IBR is the escape route. Step-by-step: defaulted loans in 2026.

FORCED in (no choice at all)

Anyone whose first federal loan is on or after July 1, 2026

Two plans exist for you: RAP and Tiered Standard. That's the menu. If you want income-driven payments or PSLF, RAP is it.

Existing borrowers who take ANY new federal loan on or after July 1, 2026

LOCKED OUT (RAP forbidden)

Parent PLUS borrowers

Parent PLUS loans can't use RAP — and neither can any consolidation loan that contains one, no matter what else is in it. One Parent PLUS loan poisons the whole consolidation. Parents have a different, narrower map — a time-boxed IBR pathway and the Tiered Standard plan — and a countdown of their own. Everything is in the exclusion explainer and the Parent PLUS options guide.

FFEL and Perkins borrowers (without consolidating)

RAP is a Direct Loan program. Old FFEL or Perkins loans must first be consolidated into a Direct Consolidation Loan to reach it — a move with its own trade-offs (interest rate rounding, restarting certain clocks) covered in the eligibility checklist.

The one-table summary

The five borrower cohorts, sorted

The conversion trigger: the rule that surprises everyone

Row five deserves its own section because it's retroactive in effect and nobody's servicer will warn them. The statute doesn't grandfather borrowers — it grandfathers portfolios that stay closed. A 2015 graduate comfortably weighing RAP against IBR loses that choice the day a single new disbursement posts: a certificate program's $3,000 loan, a grandfathered Grad PLUS draw, one semester back at school. From that day, IBR — and its 20/25-year forgiveness clock, and its payment cap — is deleted for the 2015 loans too. If continued education is anywhere in your plans, the sequencing question ("what does this loan do to my existing repayment rights?") belongs in the enrollment decision itself, priced against alternatives like employer tuition benefits or cash-flowing a cheap program. The grad borrowing page covers the school-side rules.

Involuntary placement: what "do nothing" actually gets you

Both forced cohorts share a failure mode: miss your window and the system moves you without judgment. What automatic placement ignores: your PSLF track (it can drop you into a non-qualifying plan or an income-driven plan whose payment your filing status inflates), your MFS strategy, your clock-credit position, and your budget. The choice you'd have made is almost always available inside the window at zero cost — the entire penalty of the transition is concentrated on people who let deadlines choose for them. Ten minutes at StudentAid.gov versus a default that fits nobody: that's the trade this page exists to prevent.

Edge cases the sorting rules miss

Four profiles that don't fit the clean boxes. Mixed portfolios — old loans plus one new post-July-2026 loan: the new borrowing converts your whole menu; one $3,000 loan for a final semester can drag $80,000 of old debt into RAP-only territory, so exhaust alternatives for small final-year gaps. In-school and grace-period borrowers: your plan election happens at repayment entry, but your disbursement dates already decided your menu — know which side of the line each loan sits on before the first bill. Rehabilitated defaulters: you exit default into the current menu, not the one from when you borrowed; run the sort fresh, per the default playbook. Joint spousal consolidation holders: your separation process runs first, sorting runs second — start early; nothing about that queue is fast. When in doubt, the loan inventory at studentaid.gov is the ground truth: disbursement dates and loan types answer every sorting question this page asks.