8 Things to Watch for the 2026 ACA Open Enrollment Period

The Affordable Care Act (ACA) Marketplace Open Enrollment season starts November 1, 2025 in most states. The premiums insurers charge are increasing. And, with enhanced premium tax credits set to expire at the end of the year, out-of-pocket premiums are expected to increase drastically. Additionally, changes to Marketplace enrollment and eligibility rules in this year’s budget reconciliation law and in the Trump Administration’s “Marketplace Integrity and Affordability” regulation (program integrity regulation) include other changes to open enrollment.

Here are the eight things to know for the 2026 Open Enrollment period.

1. Enhanced premium tax credits are set to expire.

Currently, enhanced premium tax credits provide extra financial assistance to ACA Marketplace enrollees who are eligible for subsidies, and make middle-income enrollees (those with incomes above four times the poverty level) eligible for financial help, unlike in the original ACA. These enhanced tax credits will expire at the end of the year unless Congress acts to change the law.

Looking ahead to 2026, the future of the enhanced premium tax credits remains uncertain. Without enhanced tax credits, KFF estimates that subsidized Marketplace enrollees’ out-of-pocket premium payments will be 114% higher, on average.

These increases in enrollees’ monthly premium payments will vary from person to person. If enhanced tax credits expire, people with incomes below four times poverty ($62,600 for an individual, $128,600 for a family of four) will continue to receive a tax credit, but the amount of financial help they receive could be significantly less. People with incomes above four times poverty will no longer be eligible for financial help and will be hit by a double whammy of lost tax credits and rising costs from insurers if enhanced tax credits expire. A KFF calculator allows users to input a zip code, income, and age to see 2026 premium payments with or without an extension of the enhanced tax credits.

While these tax credits do not expire until the end of 2025, if Congress does not extend the subsidies at least a few days before the enrollment window opens, Marketplace enrollees will log on and see these higher premiums as soon as open enrollment starts on November 1. The Congressional Budget Office projects significant coverage losses, and insurers expect younger, healthier enrollees to be more likely to drop their Marketplace plans, which will in turn push premium increases even higher than they otherwise would be. 

2. Marketplace enrollees could have to repay more at tax time.

Currently, an enrollee who makes less than 400% of the federal poverty level and whose income ends up being higher than they had estimated at the time they signed up must repay some of the excess premium tax credit on their taxes the following year, up to a repayment limit.

Starting in the 2026 plan year, due to changes made in the 2025 budget reconciliation law, tax credit repayment limits will be eliminated, and Marketplace enrollees will be expected to repay the full amount of any excess tax credits when they file their 2026 taxes.

Additionally, if enhanced premium tax credits expire, and the “subsidy cliff” returns for people with incomes over four times the federal poverty level, enrollees who start out with expected incomes below four times poverty but end up with actual incomes above four times poverty will have to pay back the entire tax credit, which could be thousands or even tens of thousands of dollars.

Marketplace enrollees, who are often self-employed, shift, or gig-workers, tend to have high income volatility, potentially leaving them subject to significant repayments. If an enrollee experiences a mid-year change in their expected earnings, they can notify the Marketplace to adjust their coming months’ tax credit to minimize repayments at tax time.

3. Program changes might result in more Marketplace enrollees selecting higher deductible plans.

With the expiration of enhanced premium tax credits, many ACA Marketplace enrollees facing higher monthly premium payments next year may decide to switch from a silver or gold plan to a bronze or catastrophic plan to keep a lower premium payment, but the tradeoff would be a much higher deductible.

The Trump administration announced plans to expand access to catastrophic health plans on the Federally Facilitated Marketplaces and some State-Based Marketplaces. Citing a “significant rise in health insurance premiums,” CMS will streamline the process for individuals to receive a “hardship exemption” if they are not eligible for premium tax credits or cost sharing help because their projected income is below the federal poverty level or above 250% of the federal poverty level. These individuals will be allowed to enroll in a catastrophic plan where they are available on or off the Marketplace. These plans have lower premiums than bronze plans but have an annual deductible of $10,600 for an individual or $21,200 for a family in 2026.

Additionally, the budget reconciliation law included changes to health savings account (HSA) rules that will automatically treat all Marketplace bronze and catastrophic plans as high-deductible health plans (HDHP), making them eligible to be paired with an HSA. In the past, not all bronze or catastrophic plans with high deductibles available on the Marketplace could be used with an HSA. This change could increase use of HSAs in the Marketplace. The budget reconciliation law also now allows all HDHPs with an HSA to cover telehealth and other remote services before the enrollee meets the deductible.

4. Premium tax credit eligibility will be eliminated for certain lawfully present immigrants.

Currently, lawfully present immigrants with incomes below 100% FPL who are ineligible for Medicaid because they have been in the U.S. less than five years are eligible for subsidized ACA Marketplace coverage.

Starting in 2026, lawfully present immigrants who are not eligible for Medicaid due to their immigration status and who have incomes below 100% FPL will no longer be eligible for subsidized Marketplace coverage.

Additionally, starting in 2027, the budget reconciliation law further restricts eligibility for subsidized Marketplace coverage only to certain lawfully present immigrants. These individuals include:

• Lawful permanent residents
• Cuban and Haitian entrants, as defined in section 501(e) of the Refugee Education Assistance Act of 1980
• Any lawful residents living in the U.S. under the Compact of Free Association

This means other lawfully present immigrants such as refugees, asylees, and survivors of human trafficking will no longer be eligible for premium tax credits starting in 2027.

5. Consumers with lower incomes can no longer sign up year-round.

In recent years, consumers with estimated incomes less than or equal to 150% of the federal poverty level (FPL) ($23,475 for an individual, and $48,225 for a household of 4 in 2026) could enroll in Marketplace coverage at any point throughout the year, not just during Open Enrollment, in what was called the “low-income special enrollment period” (low-income SEP). Insurers had expressed concern that this year-round opportunity to enroll in and switch plans was leading to adverse selection as lower-income people could wait until they were sick to sign up or switch to a more generous plan.

Starting August 25, 2025, a consumer can no longer qualify for an SEP just because they have a low income. This change, included in the program integrity regulation, will expire at the end of plan year 2026; however, a provision of the budget reconciliation law that takes effect in 2026 will effectively end the low-income SEP permanently. This change will prohibit most consumers from receiving a premium tax credit if they enroll in Marketplace coverage through an income-based SEP, such as the low-income SEP.

6. Loss of federal Navigator funding could make it harder for some consumers to find help during open enrollment.

In February 2025, the Centers for Medicare & Medicaid Services (CMS) announced a 90% reduction in federal Navigator funding, reducing funding from $100 million last year to $10 million for the 2026 plan year. This cut will significantly reduce the resources available to nonprofit and community organizations that help consumers with navigating coverage changes, selecting plans, and applying for premium tax credits, among other services. For example, Navigators in the state of Louisiana were awarded $2,467,867 last year. This year they were awarded $250,000. In North Carolina, funding was reduced from $7,434,368 in 2025 to $750,000 in 2026.

While agents and brokers have facilitated an increasing number of enrollments for HealthCare.gov, unlike Navigators, agents and brokers are financially compensated by private insurers for enrolling people in plans. Recent Department of Justice indictments have involved allegations that some brokers have fraudulently enrolled consumers or switched their Marketplace coverage to obtain commission payments from insurance companies.

7. Deferred Action for Childhood Arrivals (DACA) recipients will be unable to sign up for Marketplace coverage.

A Biden administration regulation from 2024 allowed DACA recipients to enroll in Marketplace or Basic Health Program (BHP) coverage and access premium tax credits and cost-sharing reductions.

As of August 25, 2025, due to the Trump Administration program integrity rule, DACA recipients are no longer eligible for Marketplace coverage, premium tax credits, cost-sharing reductions, or BHP coverage in states that operate one. No DACA recipients can enroll after that date, and, in most states, those already enrolled in Marketplace coverage lost this coverage effective September 30, 2025.

8. Several planned regulatory changes to ACA Marketplace coverage have been temporarily blocked by a federal court.

The Trump Administration issued a program integrity rule that makes substantial changes to Marketplace enrollment processes and eligibility for premium tax credits, aimed in part at reducing fraudulent enrollment. These changes were scheduled to go into effect for the 2026 plan year. However, many of these changes have been temporarily halted by a federal court in Maryland.

In a case called City of Columbus et. al v. Kennedy, plaintiffs question the authority of the Trump Administration to make many of these changes, alleging that the Administration either exceeded their authority under the ACA or failed to make the case that these new eligibility and enrollment restrictions were warranted. The court granted a preliminary injunction in August blocking the implementation of several parts of the program integrity rule, including additional paperwork requirements for certain consumers to verify their income to be eligible for premium tax credits. Also, the court temporarily blocked a requirement that returning Marketplace enrollees who would otherwise be automatically reenrolled into a zero-premium plan pay a new five-dollar monthly premium until they actively reenroll. A list of the stayed provisions is available here.

It is expected that this case (and a related one) will take several months to be resolved, so consumers may not see these stayed provisions in effect soon, if at all.