What the subsidy actually is. Under 20 U.S.C. 1078(a)(1) and (a)(3)(A) the borrower is entitled to have interest paid on their behalf for two statutory periods: interest accruing before the student ceases to carry at least one-half the normal full-time academic workload, and interest accruing during a period in which principal need not be paid, which covers qualifying deferments. The six-month grace period is added by regulation rather than by that statutory language: 34 C.F.R. 685.102 provides that the Secretary subsidizes the interest "while the borrower is in an in-school, grace, or deferment period". There is one historical exception, and it still affects people repaying today — the grace period was not subsidized on loans first disbursed between 1 July 2012 and 1 July 2014, so a borrower from those two cohorts entered repayment owing slightly more than they borrowed. The practical effect otherwise is that a subsidized loan enters repayment at the amount borrowed, while an unsubsidized loan of the same size enters repayment owing the amount borrowed plus several years of accrued interest. That accrued interest is no longer folded into principal merely because repayment has begun. The Department eliminated every instance of capitalization not required by statute with effect from 1 July 2023, and 34 C.F.R. 685.202(b)(2) now capitalizes unpaid interest on a loan not eligible for interest subsidies only "upon the expiration of the deferment." The interest is still owed either way; what changed is whether it starts earning interest of its own.
It is still available, and that is worth saying plainly because the 2025 overhaul of federal student lending is widely assumed to have ended it. The only termination of subsidized lending anywhere in Public Law 119-21 is a re-enactment, under a new heading, of a rule that has been in force since 2012: graduate and professional students may not receive one for any period of instruction beginning on or after 1 July 2012. The Department of Education's own final rule implementing the Act states that the undergraduate loan limits in 34 C.F.R. 685.203 remain unchanged. There is no sunset date for undergraduate subsidized loans.
Need-based means the amount is capped by need, not that need is a yes-or-no test. For a subsidized loan, 34 C.F.R. 685.203(j)(1) caps the loan at the student's cost of attendance for the period of enrollment, less other financial assistance, less the student aid index. That third subtraction is exactly what makes the loan need-based and is the one an unsubsidized loan does not have. In practice, though, the annual limit usually bites long before the need calculation does.
The limits are fixed figures, not indexed ones. Annual subsidized borrowing under 34 C.F.R. 685.203(a) is capped at $3,500 for a student who has not completed the first year of an undergraduate program, $4,500 after the first year, and $5,500 after the second, for a program of at least a full academic year. Paragraph (d)(1) caps total subsidized borrowing for an undergraduate at $23,000. A separate combined ceiling applies to subsidized and unsubsidized borrowing together, at $31,000 for a dependent undergraduate and $57,500 for an independent one. These are stated in dollars in the regulation and are not adjusted for inflation, which is why they have not moved in years and why they buy steadily less.
What the subsidy does not cover. The interest rate is set once a year by a statutory formula and is then fixed for the life of that loan, so each year's borrowing can carry a different rate; the current rate is published by the Education Department. A loan fee is deducted from each disbursement, set at 1 percent of principal by 20 U.S.C. 1087e(c) for loans first disbursed on or after 1 July 2010, so slightly less money reaches the school than the amount borrowed and appears on the balance. The Education Department publishes the exact percentage it deducts for each disbursement window, so that is the figure to check rather than the statutory one. The cost of attendance rules include an allowance for that fee for exactly this reason.