Since its inception, the Affordable Care Act (ACA) has gone through many changes, and 2026 will see some of the most significant shifts yet. Between the sweeping budget bill passed in July and new administrative rules from CMS, a host of changes are coming that will affect ACA affordability, enrollment and eligibility. Both individuals and employers need to prepare; Families may see premiums rise, enrollment deadlines shrink, and eligibility rules tighten. Businesses should expect ripple effects in group health plans as costs shift across the market.
Expiring Subsidies
The thing that will likely give individuals the most sticker-shock this fall is the expiration of enhanced ACA subsidies. While subsidies have always been a part of the ACA, during the pandemic they were generously increased and extended by Democratic administrations, making coverage much cheaper for millions of Americans. But they were never made a permanent part of the law and are set to expire at the end of 2025.
More than 90% of ACA enrollees receive subsidies, saving an average of $700 per year
More than 90% of ACA enrollees receive subsidies, saving an average of $700 per year, according to KFF. Without these enhanced subsidies, most people buying coverage through the ACA marketplace would see their monthly premiums go up by about 75%. This will likely cause a lot of healthy individuals to drop coverage due to the increased up-front cost, leaving a sicker, more costly insurance pool.
Health insurers are already planning for this reality, with sharp increases expected for 2026.
Higher Premiums on the Horizon
Every year in mid-August — when insurers submit their rate filings for the year ahead — we start to get a clearer picture of where premiums are headed. This timing is important because it gives families, individuals, and employers prepare for what’s coming before open enrollment begins.
Insurers are requesting a median rate increase of 18% for 2026.
For 2026, the outlook is steep. A recent analysis by Peterson-KFF of 321 insurers in the market showed that they are requesting a median rate increase of 18%. This is a significant jump at 11 points higher than last year and the largest increase since 2018.
Insurers point to several factors driving these increases; The rising cost of health care and labor, the high price of specialty drugs, and the impact of tariffs and federal policy changes.
Employers aren’t spared either: the Business Group on Health’s 2026 Employer Health Care Strategy Survey projects group health premiums will rise by about 9% in 2026, marking the third consecutive year of higher-than-expected increases.
For employers, these rising costs may mean adjusting cost-sharing strategies while staying within ACA affordability rules. Those already offering an ICHRA or QSEHRA might also want to consider increasing contribution amounts to help employees manage higher premiums.
Learn more about Benafica’s ICHRA
More Hurdles to Enrollment and Re-Enrollment
While premiums are a major concern, it’s not the only challenge ahead. 2026 will also bring major changes to the way people sign up for and keep their coverage.
Shorter Open Enrollment Window: A new rule would shorten the ACA open enrollment period, moving the end date from January 15 to December 15. During the most recent open enrollment period for 2025, over 40% of all enrollees signed up after December 15. Cutting that window would risk losing access to coverage for a significant number of people.
- Effective date: This will begin for the 2027 plan year, so fall of 2026 open enrollment period will be shorter. 2025’s open enrollment period will be unchanged, from Nov 1st – Jan 15th.
End of Year-Round Enrollment for Low-Income Families: Previously, low-income individuals (up to 150% of the poverty line) were allowed to sign up for health insurance at any time of the year. This enrollment option is being removed in 2026, along with eligibility for subsidies for income-based SEP enrollees. Without it, many people who miss the shortened open enrollment period may have to go without coverage until the following year.
- Effective date: Starting in 2026. So, low-income families need to make sure they enroll by January 15th, 2026.
More Hurdles to Enroll: New up-front income verification rules mean applicants can no longer simply “self-attest” their income when signing up. Instead, they’ll need to provide documentation before being approved for coverage, adding an extra step that could delay or block enrollment for some households.
- Effective date: August 25, 2025.
End of Automatic Re-Enrollment: In past years, most people were automatically re-enrolled in their plan if they didn’t take action during open enrollment. Starting in 2026, that’s changing. Everyone will be required to verify their income and eligibility each year to keep their coverage, meaning individuals must take action or risk losing their plan altogether.
- Effective date: For enrollees with $0 premiums, they will have to actively re-enroll and update information in the 2025 open enrollment period. For all others, the end of automatic re-enrollment applies to everyone starting in 2028.
DACA Recipients and New Immigrants Lose Eligibility: DACA recipients will lose their eligibility to purchase coverage on the ACA Marketplace, reversing the Biden administration’s 2024 rule that opened access to them. In addition, new immigrants who earn under 100% of the federal poverty line will no longer qualify for subsidized plans, even though they were previously allowed to enroll with financial help.
- Effective date: For DACA recipients, the effective date is August 25, 2025 (will be disenrolled from plans after this date.) For new immigrants, the effective date is Jan 1st, 2026.
The Bottom Line: Preparing for 2026
The 2026 changes stand out for how broadly they affect both affordability and access. The main takeaway is that everyone needs to prepare for the reality that fewer healthy enrollees mean higher costs for everyone.
For individuals, that means paying closer attention than ever — comparing premiums, covered benefits, and out-of-pocket costs before settling on a plan, and bracing for higher monthly costs across the board.
For employers, the ripple effects may shape benefit strategies not just next year but for years to come. Beyond managing rising group premiums, businesses will play an important role in helping employees understand new enrollment deadlines, documentation requirements, and alternative coverage options. Staying informed and prepared will be key to navigating what’s next.