Federal Student Aid Updates

Last updated on July 16, 2026

The One Big Beautiful Bill Act (OB3) was signed into law on July 4, 2025 with provisions going into effect on July 1, 2026. The U.S. Department of Education is currently working to provide guidance about this law which introduces significant changes to federal student aid programs. While some provisions are clear, many others require further clarification from the U.S. Department of Education. We understand that students, families have questions — and so do we.

As we receive more guidance and official updates, we will continue to revise and expand this webpage to reflect the most accurate and actionable information available.

The University of Dayton is committed to supporting students through these changes to federal financial aid by:

  • Working with federal and state agencies to advocate for students.
  • Preparing resources and planning tools for students and families as new rules are finalized.
  • Updating advising and financial aid processes to ensure students receive accurate, timely information.

Upcoming federal changes under H.R. 1, the One Big Beautiful Bill Act (OB3), are listed on this page. Most provisions take effect July 1, 2026, and some details are still being finalized by the U.S. Department of Education.


Federal Student Loan Limits

The "Loan Limits for Legacy Borrowers" column continues for borrowers who meet legacy conditions.

Federal Student Loan Limits Under Previous Law and OB3
Category of Borrower Loan Limits for Legacy Borrowers Loan Limits for New Borrowers Under OB3
Undergraduate Students $5,500 to $12,500 annually;
$31,000 to $57,500 in aggregate
$5,500 to $12,500 annually;
$31,000 to $57,500 in aggregate
Nonprofessional Graduate Students $20,500 or the Cost of attendance (as defined by the institution); whichever is less $20,500 annually;
$100,000 in aggregate
Professional Graduate Students $20,500 or the Cost of attendance (as defined by the institution); whichever is less $50,000 annually;
$200,000 in aggregate
Parents of Undergraduates Cost of attendance (as defined by the institution) $20,000 annually;
$65,000 in aggregate (per child)

Source: U.S. Department of Education, Federal Student Aid, and One Big Beautiful Bill Act, H.R. 1, 119th Cong. (2025).

There is a new lifetime limit in effect of $257,500 for all combined federal student loans. This includes the amount that a student has borrowed previously through the Federal Graduate PLUS loan. Legacy borrowers are not subject to this lifetime limit.


Undergraduate Student Financial Aid Changes


Parent PLUS Loan Limits

What is changing?

Parent PLUS Loan Limits are changing.

  • Annual limit: $20,000 per year, per student
  • Lifetime limit: $65,000 per student

Who is impacted by this change?

  • Only new undergraduate student borrowers are subject to these limits.
  • Previous legacy borrowers are any students enrolled at UD as an undergraduate student who has borrowed any federal loan prior to July 1, 2026.
  • This legacy condition for previous borrowers remains in effect for three academic years or for the remainder of their expected time to complete the program, within the published length of time to do so, whichever is less.
  • Current borrowers meeting the legacy provision are only eligible for this for a limited period of time (usually no more than 3 years). If your program enrollment extends beyond the allowable "legacy" window of 3 years, you will be subject to the new annual and lifetime loan limits.
Examples
  • You have received federal loans for the past two years (prior to July 1, 2026) and change your major at UD. In this case, you are considered a legacy borrower.
  • You have received federal loans for the past two years (prior to July 1, 2026) as an undergraduate and now enroll as a graduate MBA student. In this case, you are considered a new borrower.
  • You received federal loans last year at another institution and transferred to the University of Dayton to continue your undergraduate degree. In this case, you are considered a new borrower.

What should parent borrowers do to prepare?

Parent borrowers should plan carefully. Those that are borrowing more than $20,000 annually or plan to borrow more than $65,000 over the course of the student’s undergraduate degree should consider both private and federal loan options.


Federal Direct Loan Eligibility for Less than Full-Time

What is changing?

Eligibility for annual Federal Direct Loan amounts are reduced for students who are enrolled less than full-time in an academic year (24 credit hours). Anytime enrollment falls below full-time, federal student direct loans must be reduced according to a schedule of reduction (SOR). This could affect loan eligibility for future terms and could result in a balance due if drops are made after the refund period.

Is there a legacy provision for this reduction in eligibility based on less than full-time enrollment?

No, this provision is effective for any student enrolled less than full-time after July 1, 2026.

How should I plan my enrollment?

Because future loan disbursements will be tied more closely to full-time enrollment, students will want to plan their schedules carefully starting in 2026–2027. If you have less than full-time enrollment in any term, it could affect loan eligibility in later terms. Your academic advisor can help you map out a schedule that keeps you on track. Completing a minimum of 24 credit hours in an academic year will ensure that you don’t have reduced eligibility for federal student direct loans.

Will taking classes part-time reduce the amount of federal loans that I can borrow?

Yes, under the new law your loan eligibility is adjusted based on your total annual enrollment. If you enroll less than full-time in an academic year (a total of 24 credit hours), your available annual loan amount will be reduced.


Federal Pell Grant Limit

What is changing?

The Federal Pell Grant can no longer exceed the student's Cost of Attendance when combined with other financial aid.

Who is affected by this change?

This affects a very small population of students and our office will communicate directly with them by early April 2026. Federal Pell grant eligibility will continue to be awarded based on the FAFSA determined eligibility for most students.



Doctoral, Graduate and Law Student Financial Aid Changes


Graduate PLUS Loan

What is changing?

The Graduate PLUS loan has been eliminated for new student borrowers.

Who continues to be eligible for the Graduate PLUS loan?

Any student who has borrowed any federal loan prior to July 1, 2026 and meets the following conditions is eligible for the Graduate PLUS Loan:

  • Enrolled in the same graduate program for up to three academic years or for the remainder of their expected time to complete the program, within the published length of time to do so, whichever is less.
  • Has not ceased enrollment after July 1, 2026.
  • Students must continue to be credit approved.
Examples
  • You have received federal loans for the past year (prior to July 1, 2026) as a DPT student and will be taking another loan this year for the same program. In this case, you are considered a legacy borrower.
  • You are starting a new degree program after July 1, 2026 and have not previously borrowed federal loan money for this program. In this case, you are considered a new borrower.

What happens if I change my degree program of study after July 1, 2026 or take a leave of absence?

Beginning a new degree program (even at the same school), or taking a leave of absence can reset your borrowing category. This means your loan limits and eligibility rules may change to those of a "new borrower."

If completion of my program extends longer than expected, do I retain my original borrowing category?

Current borrowers meeting the legacy provision are only eligible for this for a limited period of time (usually no more than 3 years). If your program enrollment extends beyond the allowable "legacy" window of 3 years, you will be subject to the new annual and lifetime loan limits.

What other aid is available if I am not eligible for the Graduate PLUS loan?

The University of Dayton has evaluated lending opportunities available to students in the private marketplace and we have a list of lenders which can be a starting point for you to explore. Students are not required to use a lender on this list, rather they can consider any lender they choose.


Federal Direct Loan Eligibility for Less than Full-Time

What is changing?

Eligibility for annual Federal Direct Loan amounts are reduced for students who are enrolled less than full-time in an academic year. Anytime enrollment falls below full-time, federal student direct loans must be reduced according to a schedule of reduction (SOR). This could affect loan eligibility for future terms and could result in a balance due if drops are made after the refund period.

What is considered full-time for my program?

What Is Considered Full-Time
Program of Study Full-Time Per Semester
JD - Law Degree 12 or more hours
Ed.D. 6 or more hours
DPT 6 or more hours
PA 6 or more hours
All other master’s or Ph.D. programs 6 or more hours

Under the new bill, your loan eligibility is adjusted if you are not enrolled full-time during the academic year. The academic year calculation includes the summer term if it is a required term of enrollment for your program (ex. DPT and physician assistant programs).

Is there a legacy provision for this reduction in eligibility based on less than full-time enrollment?

No, this provision is effective for any student enrolled less than full-time after July 1, 2026. We encourage you to plan your schedule for each of the terms for the upcoming academic year while details about this requirement are still being finalized.

Will taking classes part-time reduce the amount of federal loans that I can borrow?

Yes, under the new law your loan eligibility is adjusted based on your total annual enrollment. If you enroll less than full-time in an academic year, your available annual loan amount will be reduced.


Federal Direct Unsubsidized Loan Limits

What is changing?

Effective July 1, 2026, the Federal Direct Unsubsidized Loan limits are different for graduate and professional students. Before this, the limits were the same.

Who is impacted by this change?

Only new student borrowers are subject to these limits.

Previous legacy borrowers are any students enrolled in the same graduate program for up to three academic years but no longer than their expected time to credential. Additionally, a student may not cease enrollment after July 1, 2026.

Examples
  • You have received federal loans for the past year (prior to July 1, 2026) as a J.D. Law student and will be taking another loan this year for the same program. In this case, you are considered a legacy borrower.
  • You are starting a new degree program after July 1, 2026 and have not previously borrowed federal loan money for this program. In this case, you are considered a new borrower.

What are the current borrower and new borrower limits?

See table for borrower limits.

NOTE: There is a new lifetime limit in effect of $257,500 for all combined federal student loans. This includes the amount that a student has borrowed previously through the Federal Graduate PLUS loan. Legacy borrowers are not subject to this lifetime limit.

What programs meet the definition of “professional”?

Based on federal guidance, at the University of Dayton, the J.D. program within the School of Law meets the definition of "Professional."

On June 23, a federal court order stayed, or temporarily halted, key parts of the U.S. Department of Education's professional degree definition. While the department is appealing the ruling, it issued guidance clarifying how schools can treat professional degree programs for loan limit purposes. The guidance includes an updated list of programs temporarily eligible for higher professional degree program loan limits. View additional details about what this may mean for your program.

This is only a distinction for loan eligibility purposes and does not reflect the academic expertise or rigor of a program.

All other programs are considered "graduate" level for federal loan eligibility.