ACA Marketplace Changes for 2026

Handling the Affordable Care Act (ACA) in 2026 involves significant updates for both individuals and employers. Individuals need to focus on accurate reporting and proactive plan management to avoidpenalties or loss of tax credits. Employers (ALEs) will be facing increased affordability thresholds and stricter IRS scrutiny.

Major Premium Increases Expected
Premiums in 2026 are projected to rise sharply. With the expiration of enhanced premium tax credits at the end of 2025, many subsidized enrollees could see their premiums jump by as much as 114%. Rising medical and prescription costs are further driving up insurance prices, making plan selection more important than ever.

Changes to Premium Tax Credits
Enhanced subsidies expired on December 31, 2025, unless Congress extends them. Middle-income families may lose eligibility, and stricter income verification rules increase the risk of subsidy repayment. According to the Congressional Budget Office (CBO), more than 4 million Americans could lose coverage without an extension.

Cost-Sharing and Plan Design Updates

• Maximum out-of-pocket limits for 2026 are $10,600 for self-only coverage and $21,200 for families.
• Many insurers have updated networks and drug formularies.
• Auto-renewing your plan may no longer be safe—benefits could have changed significantly.

Individuals should review their coverage options carefully and confirm that their selected plan continues to meet their needs and budget.

Key Changes for 2026
Employers, particularly Applicable Large Employers (ALEs), face several critical updates:

• The definition of "affordable" coverage increases to 9.96% of an employee's household income, up from 9.02% in 2025.
• Penalties for non-compliance are higher:
  • $5,010 per employee for offering unaffordable coverage or failing to provide minimum value.
  • $3,340 per employee for failing to offer coverage to at least 95% of eligible staff.

Action Steps for Employers:

1. Review and Adjust Plans
   Confirm your lowest-cost, self-only plan meets the new affordability threshold.
   
   
2. Update Payroll Systems
   Ensure payroll and HR systems reflect the new IRS percentages (133%-400% FPL) for affordability calculations. Coordinate with your payroll provider.
   
   
3. Maintain Proper Documentation
   Track which employees are offered coverage and retain signed records for those who decline.
   
   
4. Monitor Employee Decisions
   Changes in affordability may shift employee enrollment choices.

Proactive planning now will reduce the risk of costly penalties and help employees maintain access to necessary coverage.

Bottom Line

2026 is a year of adjustment under the ACA. Individuals should review their plans and subsidies carefully, while employers must update their coverage offerings, payroll systems, and compliance processes. Early action is key to avoiding surprises and maintaining coverage for employees and families.