Is Medical Debt on Credit Reports in 2026?

No. There is no federal rule in 2026 that keeps medical debt off your credit report. The rule that would have done it was vacated in full on 11 July 2025 by the U.S. District Court for the Eastern District of Texas in Cornerstone Credit Union League v. Consumer Financial Protection Bureau.

What protects you now is three separate things, and none of them is a federal regulation: the credit bureaus’ own voluntary policy, your state’s law, and which scoring model a lender happens to pull. This page covers all three, with the source and date for each.

Last reviewed: 11 September 2026. This is live litigation and live regulation, so the date matters.

What the court actually did on 11 July 2025

The CFPB finalised the Medical Debt Rule, formally “Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V),” on 7 January 2025. It was published at 90 Fed. Reg. 3276 on 14 January 2025. It would have barred consumer reporting agencies from putting medical debt in a report sent to a creditor for a credit decision, and barred creditors from considering medical debt at all.

Two trade associations sued. Then, on 30 April 2025, the CFPB switched sides and joined the plaintiffs in asking the court to throw out its own rule.

Judge Sean D. Jordan granted that joint motion. The order, in Civil No. 4:25-CV-16-SDJ, Eastern District of Texas, Sherman Division, signed 11 July 2025, states that the Medical Debt Rule “is hereby SET ASIDE and VACATED.”

The reasoning matters for everything below. The opinion opens by stating that the Fair Credit Reporting Act “permits consumer reporting agencies (‘CRAs’) to report information about consumers’ medical debt that has been coded to protect their medical privacy.” That coding permission sits at 15 U.S.C. 1681c(a)(6), which lets a bureau report a medical furnisher’s details when they are “restricted or reported using codes that do not identify” the provider or the service. The court’s view was that the CFPB cannot prohibit by regulation what the statute expressly allows.

Vacatur is nationwide. The rule never took effect, and it is not coming back in the same form.

So what actually keeps medical debt off a credit report in 2026?

Three layers, in the order that matters to you.

Layer one: the bureaus’ voluntary policy

On 18 March 2022, Equifax, Experian and TransUnion issued a joint announcement changing how they handle medical collections. The three commitments, in their own words:

1. “Effective July 1, 2022, paid medical collection debt will no longer be included on consumer credit reports.”
2. “the time period before unpaid medical collection debt would appear on a consumer’s report will be increased from 6 months to one year.”
3. “In the first half of 2023, Equifax, Experian and TransUnion will also no longer include medical collection debt under at least $500 on credit reports.”

The companies said those measures “will remove nearly 70% of medical collection debt tradelines from consumer credit reports.” The National Consumer Law Center records the under-$500 change as taking effect in spring 2023.

This is company policy. It is not in the FCRA, it was not adopted through notice and comment, and no agency enforces it as a rule. The three bureaus can narrow it whenever they choose. It is currently the single most protective thing in the whole stack, and it is also the least legally durable.

Layer two: your state’s law

Fifteen states have enacted statutes limiting medical debt in credit reports. They do not all do the same thing. Some restrict the credit bureaus, some restrict furnishers (the providers and collectors who send data in), and some restrict creditors from using the information. Full table below.

Layer three: the scoring model

Even when a medical collection is legitimately on your file, several widely used models either discount it or ignore it outright.

Is your state law still good law? The preemption fight, stated honestly

This is the genuinely unsettled part, and it deserves both sides.

The case for preemption. In Cornerstone, the court wrote at *12: “any state law purporting to prohibit a CRA from furnishing a credit report with coded medical information would be inconsistent with FCRA and therefore preempted.”

The CFPB then went further. On 28 October 2025 it issued an interpretive rule, “Fair Credit Reporting Act; Preemption of State Laws,” published at 90 FR 48710 and applicable that same day. Its stated purpose is “to clarify that the Fair Credit Reporting Act (FCRA) generally preempts State laws that touch on broad areas of credit reporting.” It replaced a July 2022 interpretive rule, withdrawn in May 2025, which had concluded that 15 U.S.C. 1681t(b)(1) “does not preempt all State laws relating to the content or information contained in consumer reports.”

The 2025 rule uses medical debt as its own worked example. It argues that if a state set a one-day obsolescence period for medical debt information, that would clearly be preempted under section 1681t(b)(1)(E), so a state banning the same information outright should be preempted too: “It would make no sense to forbid the former but allow the latter.”

The case against. The National Consumer Law Center’s position is that the Cornerstone preemption language is dicta. NCLC’s reasons are specific: the validity of state statutes “was not before the court, not briefed, and not necessary for the court’s final judgment,” the final judgment contains no order or injunction touching any state law, and the court’s preemption discussion cited no case law at all.

That last point is the sharp one. NCLC notes the court did not address Consumer Data Industry Association v. Frey, 26 F.4th 1 (1st Cir. 2022), in which the First Circuit held that a state restriction on reporting medical debt was not preempted. NCLC’s conclusion: “the dicta in Cornerstone has no legal effect in the fifteen states that have adopted prohibitions against medical debt credit reporting.”

It is also worth noting what an interpretive rule is. It does not go through notice and comment and it does not bind a court. The CFPB says as much inside the document itself, quoting Supreme Court precedent that “agencies have no special authority to pronounce on pre-emption absent delegation by Congress.” That line is in the rule as a criticism of the 2022 interpretation, but it applies with equal force to the 2025 one.

What the record supports, and nothing more. All fifteen state laws remain on the books. No court has struck any of them down. Testing them would require litigation in a court with jurisdiction in each state. Anyone telling you the answer is settled, in either direction, is ahead of the record.

The 15 states with a medical debt credit reporting law

State list from the NCLC tracker “The Latest on Keeping Medical Debt Out of Credit Reports,” pulled 11 September 2026. Every date and bill number below was then checked against the enacted state text.

State	Effective	What it limits	Statute
California	1 Jan 2025	Furnishing, bureau reporting, and creditor use	SB 1061
Colorado	7 Aug 2023	Bureau reporting	HB 23-1126
Connecticut	1 Jul 2024	Furnisher reporting	Public Act 24-6
Delaware	27 Oct 2025	Furnishing and bureau reporting	SS 1 for SB 156
Illinois	1 Jan 2025	Bureau reporting	Public Act 103-0648
Maine	9 Jun 2025	Furnishing and bureau reporting	10 M.R.S. 1308, 1310-H
Maryland	1 Oct 2025	Furnishing, bureau reporting, and use	SB 614
Minnesota	1 Oct 2024	Furnishing and bureau reporting	Ch. 114, S.F. 4097
New Jersey	22 Jul 2024	Furnisher reporting of all medical debt; bureau reporting of paid debt and debt under $500	S 2806
New York	13 Dec 2023	Furnisher reporting	S 4907A
Oregon	1 Jan 2026	Furnishing and bureau reporting	SB 605
Rhode Island	1 Jul 2025	Furnishing and bureau reporting	SB 2709
Vermont	1 Jul 2025	Furnishing and bureau reporting	9 V.S.A. 2466d, 18 V.S.A. 9485(b)
Virginia	1 Jul 2024	Furnisher reporting	HB 1370
Washington	27 Jul 2025	Furnishing and bureau reporting	SB 5480

Two details people get wrong. New Jersey’s $500 figure covers only half the statute: creditors and collectors cannot report any medical debt for care performed on or after 22 July 2024, while the bar on the bureaus covers paid medical debt and debt under $500 whatever its age. And SB 605 is Oregon’s, effective 1 January 2026, not California’s. California’s is SB 1061, whose credit reporting ban took effect 1 January 2025. The 1 July 2025 date often pinned to SB 1061 is a different provision: the disclosure every medical debt contract has had to carry since then. For the per-state detail, see our companion page on medical debt on credit reports by state.

How each scoring model treats a medical collection

If a medical collection does land on your file, the damage is not one number. It depends on which model the lender pulls.

Model	Medical collections	Paid collections
FICO 8	No medical-specific treatment. Scored like any other collection	Counted
FICO 9	Unpaid medical collections have less negative impact than other unpaid collections	”Any third-party collections (including medical) that have been paid off no longer have a negative impact”
VantageScore 3.0	Medical collection data not used, regardless of amount owed or age	Ignored
VantageScore 4.0	Medical collection data not used, regardless of amount owed or age	Ignored

Sources: myFICO’s own FICO Score versions documentation lists medical-collection differentiation as a feature introduced with FICO Score 9, which is why FICO 8 has no such carve-out. VantageScore’s press release of 10 August 2022 states that neither VantageScore 3.0 nor 4.0 “will continue to use this data in the calculation of consumers’ credit scores, regardless of the amount owed or the age of the collection.” VantageScore estimated at the time that affected consumers would “likely see scores increase by as much as 20 points” under those models. That is VantageScore’s estimate for its own models, not a promise about your file.

Why this suddenly matters more. On 9 September 2026, Fannie Mae issued Lender Letter LL-2026-06, “VantageScore 4.0 Broad Lender Availability,” expanding VantageScore 4.0 to all Fannie Mae-approved lenders without prior written approval, effective immediately and coordinated with Freddie Mac. A conforming mortgage can now be underwritten on a model that ignores medical collections entirely. One caveat straight from the Lender Letter: for manually underwritten loans, “lenders must continue to only use Classic FICO.”

What to actually do, in order

1. Pull all three reports. Free weekly at annualcreditreport.com, the central source. NCLC specifically advises using the central source rather than opening an account directly with a bureau, which may require you to agree to arbitration.
2. Check the amount and the paid status against the voluntary policy. Unpaid and under $500, paid at any amount, or less than one year delinquent all mean it should not be there. If it is, that is a straightforward error. See medical debt under $500.
3. Check your state against the table above. If your state restricts furnishers rather than bureaus, your complaint may belong with the provider or collector, not the bureau.
4. Verify the debt itself. Request an itemised bill from the provider and the explanation of benefits from your insurer. Medical billing runs through an insurance layer that other debts do not have, which is where a large share of the errors originate.
5. Dispute in writing. FCRA Section 611, 15 U.S.C. 1681i(a)(1)(A), requires the bureau to conduct a reasonable reinvestigation “before the end of the 30-day period beginning on the date on which the agency receives the notice of the dispute.” That window extends by up to 15 additional days if you send further relevant information during it. Templates are in our credit dispute letter guide.
6. Escalate if nothing moves. File a complaint with the CFPB. Our walkthrough is at CFPB complaint against a credit bureau.

One limit, stated plainly. If a medical collection is accurate, genuinely yours, correctly aged, and not covered by the voluntary policy or a state law, nobody can make it disappear. Not us, not any credit repair company. It falls off seven years from the date of first delinquency under 15 U.S.C. 1681c(a)(4). More on that in how long collections stay on a credit report and what accurate information can and cannot be removed.

The short version

• No federal rule keeps medical debt off credit reports in 2026. The CFPB’s Medical Debt Rule was vacated on 11 July 2025 in Cornerstone Credit Union League v. CFPB, Civil No. 4:25-CV-16-SDJ (E.D. Tex.).
• The bureaus’ voluntary policy is doing most of the work. Paid medical collections off since 1 July 2022, a one-year delay before reporting, and nothing under at least $500 since the first half of 2023. The bureaus said this removed “nearly 70%” of medical collection tradelines.
• That policy is not law and can be changed by the three companies without a rulemaking.
• Fifteen states have their own laws. All fifteen are still on the books. None has been struck down.
• Preemption is genuinely unresolved. The Cornerstone court and the CFPB’s 28 October 2025 interpretive rule say state content laws are preempted. NCLC says that language is dicta with no legal effect, and points to Frey, 26 F.4th 1 (1st Cir. 2022), which held the opposite.
• Scoring depends on the model. FICO 8 treats a medical collection like any other. VantageScore 3.0 and 4.0 ignore medical collections entirely, which matters more since Fannie Mae opened VantageScore 4.0 to all approved lenders on 9 September 2026.

Sources

1. Cornerstone Credit Union League v. Consumer Financial Protection Bureau, Civil No. 4:25-CV-16-SDJ, Memorandum Opinion and Order, U.S. District Court for the Eastern District of Texas, Sherman Division, signed 11 July 2025 (2025 WL 1920148). Opinion text reviewed 11 September 2026.
2. Consumer Financial Protection Bureau, “Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V),” final rule issued 7 January 2025, 90 Fed. Reg. 3276 (14 January 2025). consumerfinance.gov rule page, pulled 11 September 2026.
3. Consumer Financial Protection Bureau, “Fair Credit Reporting Act; Preemption of State Laws,” interpretive rule, 90 FR 48710, published 28 October 2025, applicable 28 October 2025, 12 CFR part 1022, document 2025-19671. Pulled 11 September 2026.
4. National Consumer Law Center, “The Latest on Keeping Medical Debt Out of Credit Reports,” library.nclc.org. Pulled 11 September 2026. Source for the fifteen-state list and the dicta analysis. Dates and bill numbers cross-checked against enacted state text, including California SB 1061 (Chapter 520, 2024), New York S 4907A (signed 13 December 2023), Virginia HB 1370 and New Jersey S 2806.
5. 15 U.S.C. 1681t(b)(1) (preemption), 1681c(a)(4) and (a)(6) (information in consumer reports, medical coding), 1681i(a)(1) (reinvestigation), via Cornell Legal Information Institute. Pulled 11 September 2026.
6. Equifax, Experian and TransUnion, “Equifax, Experian, and TransUnion Support U.S. Consumers With Changes to Medical Collection Debt Reporting,” joint announcement, 18 March 2022. Pulled 11 September 2026.
7. myFICO, “FICO Score versions,” on features introduced with FICO Score 9. Pulled 11 September 2026.
8. VantageScore, “VantageScore Takes Steps to Further Support Consumers Affected By Medical Debt Collections,” 10 August 2022. Pulled 11 September 2026.
9. Fannie Mae, Lender Letter LL-2026-06, “VantageScore 4.0 Broad Lender Availability,” 9 September 2026. Pulled 11 September 2026.
10. Consumer Financial Protection Bureau, “CFPB Finds 15 Million Americans Have Medical Bills on Their Credit Reports,” 29 April 2024, reporting over $49 billion in medical bills in collections on credit reports.

Credit Booster AI reads all three of your reports in one place, flags medical collections that fall outside the bureaus’ voluntary policy or your state’s law, and generates the dispute letters. It cannot remove an accurate medical collection, and neither can anyone else.