Here the issue appears to be compelled speech. The executive can't prosecute violations if the judiciary isn't on board.

This is a little different than forgiving student loan debt owed to the fed, because the way to do that is by not taking debtors to court, i.e. due to executive inaction, the judiciary isn't involved.

I have some faith in certain circuits, like the 5th and 7th. Scotus seems to lien towards Thomas now, but who know how it will all look by the time challenges arise (assuming the bill passes and isn't vetoed).