If this is your first time applying for premium tax credits, then yes. There is no requirement to have filed a tax return for any prior year to qualify for premium tax credits. However, you must file a tax return and reconcile advance payments of premium tax credits using IRS Form 8962 for the year in which you receive them. Not doing this is called “failure to reconcile”. 

Because you have not previously filed a tax return, the Marketplace will first attempt to verify your income using electronic wage data. If the information cannot be verified electronically, you may be asked to provide additional documentation, such as pay stubs or a work contract, within 90 days.  

Beginning in plan year 2025, Marketplaces must give enrollees advance notice that they are at risk of losing their APTCs after one year of failing to reconcile. 

Once you fail to reconcile for two consecutive years, you will become ineligible for premium tax credits in the future. Note that you can still enroll in Marketplace coverage for the coming year, but premium tax credits will not be available to you until you have filed your previous tax returns with Form 8962.