The State of the ACA Market in 2026

We’ve kept tabs on the important changes in the under-65 health insurance market over the last year and what you need to pay attention to over the next year, too.

The Affordable Care Act (ACA) marketplace continues to evolve every year. Keep reading to discover why ACA health insurance options are still critical to have in your portfolio in 2026.

ACA Marketplace Enrollment Update

During the 2026 Open Enrollment Period, 22.9 million people enrolled in marketplace coverage. 3.3 million of those enrollments were first-time consumers!

State-Based Marketplace Under-65 Health Enrollments

7.2 million of the total 22.9 million marketplace enrollments came from state-based exchanges! Individual marketplaces still play a key role in the ACA market, especially as more states shift to their own platforms and away from the federal marketplace.

Did you know?

• Illinois became a state-based marketplace for the 2026 OEP. For their first OEP, they processed 441,657 enrollments on their platform, Get Covered Illinois.
• Oregon intends to transition to a state-based exchange for PY2027.
• Oklahoma plans to become a state-based marketplace for PY2028.

Our Under-65 Health team currently supports agents in both federal and state marketplaces, including: AL, AR, AZ, CA, CO, CT, DE, FL, GA, IA, IL, IN, KS, KY, LA, MD, MI, MO, MS, NC, ND, NE, NH, NJ, NY, OH, OK, PA, SC, TN, TX, UT, VA, WI, and WV.

Significant ACA Market Changes for 2025

Overall, the Trump administration continues to prioritize eliminating fraud, waste, and abuse. We’ve seen actions throughout 2025 to reduce excess spending from the federal government and protect consumers in the ACA marketplace.

Increased Government Oversight

In July, the Centers for Medicare & Medicaid Services (CMS) reported that 2.8 million Americans either enrolled in Medicaid or the Children’s Health Insurance Program (CHIP) were simultaneously enrolled in an ACA plan. CMS estimated that eliminating these overlapped enrollments will save $14 billion annually.

With the passing of the One Big Beautiful Bill, the Department of Health and Human Services (HHS) and CMS now have increased authority to audit programs such as Medicare, Medicaid, and the ACA marketplaces. We’ve continued to see increased government insight to reduce the amount of excess federal government spending.

CMS estimates that eliminating these overlapped enrollments will save $14 billion annually.

Throughout 2024 and 2025, we’ve been monitoring unauthorized ACA enrollments updates from CMS. This is an extension of CMS’ priority to not only eliminate redundancies, but also, ensure proper coverage for those who qualify.

Elimination of the 150 Percent FPL SEP

In 2025, CMS identified the 150 percent Federal Poverty Level (FPL) Special Enrollment Period (SEP) as a point of major vulnerability for improper enrollments. They discontinued the monthly SEP for households with incomes below 150 percent of the FPL for PY2026 in the 2025 Marketplace Final Rule.

In the most recent marketplace proposed rule, CMS proposed making this a permanent change.

Enhanced ACA Subsidies Discontinued

On December 31, 2025, ACA subsidies expired for those with incomes over 400 percent of the Federal Poverty Level. Individuals earning over $63,840 are now responsible for paying all premium costs associated with their ACA plan.

Individuals earning over $63,840 will be responsible for paying all premium costs associated with their ACA plan.

Premium costs are likely higher for these enrollees without subsidies.

Restricting ACA Coverage for Some Lawfully Present Immigrants

Immigrants with lawfully present status lost the ability to enroll in marketplace coverage. Dreamers became ineligible to enroll in a Qualified Health Plan (QHP) through the exchange and any state marketplace.

In the 2027 marketplace proposed rule, CMS proposes additional citizenship status verification in order to receive tax credits and ACA subsidies.

Tackle the ever-changing ACA marketplace with our comprehensive guide! Download The Complete Guide to Selling Affordable Care Act Insurance Plans today for free.

ACA Marketplace Updates for 2026

Now that we’ve covered what happened in the individual health insurance marketplace in 2025, let’s look at the updates for 2026 and beyond!

Changes to Catastrophic Coverage

In an effort to increase the amount of affordable options for consumers, more may look to catastrophic coverage and bronze-level plans. Catastrophic plans are now treated as high-deductible health plans (HDHP) and can be paired with a health savings account (HSA).

CMS has proposed expanding the hardship exemption and making additional improvements to catastrophic plans. If finalized, these plans could become available for more individuals and for longer stretches of time. Catastrophic plans could extend for multiple years with terms of up to 10 years!

Shortened Federal OEP for PY2027

The 2027 OEP for federal exchange states will be shorter than it was in 2026. It will run from November 1 to December 15, 2026.

ACA consumers in FFM states will now have only six and a half weeks to enroll in a plan on HealthCare.gov. If they miss this window and do not qualify for an SEP, they will have to wait for the next OEP to enroll.

ACA consumers in FFM states will now have only six and a half weeks to enroll in a plan.

Standardized OEP for SBMs

SBMs must start their OEPs no later than November 1 and end no later than December 31. The OEP cannot exceed nine weeks.

For example, Pennie’s OEP will run October 15 through December 15, entirely overlapping with the Medicare Annual Enrollment Period.

This could be a dramatic shift for not only your business, but also, your clients. Make sure you’re communicating these changes with your clients ahead of the OEP!

Changes Proposed by CMS in 2026

Although we’ve mentioned some adjustments from the proposed rules, there are several more we’ve not yet discussed. These policy shifts are not yet finalized but could take effect for PY2027. We will communicate this information to agents once these proposals are finalized.

Look out for:

• Stricter marketing guidelines for agents
• Increased government supervision and monitoring
• Required use of CMS-approved model consent forms
• Rolling back dental benefits for children and adults
• Eliminating third-party training vendors
• Repealing standardized plan options and plan limits

A Potential Drop in ACA Enrollments

Without expanded subsidies for those with incomes over 400 percent of the FPL, as well as other changes that could be coming to the marketplace, we may see lower enrollment numbers in 2027.

Do not fret. ACA plans are still a worthwhile product to have in your portfolio for 2026 and beyond, with millions of people enrolling in them!

Why Sell ACA Products in 2026?

Even with the changes that could be coming, the need for affordable health care and insurance isn’t changing. With rising premiums also affecting private and employer-based health care plans and potential cuts to Medicaid funding, some low- and middle-income consumers may look to the marketplace for a health plan that fits their budget.

Bronze metal tier plans can be lower in out-of-pocket costs for those who don’t need health care services often or are looking for a base level of protection by having a health care plan in case of emergency. These plans are also now HSA-eligible!

Those with catastrophic coverage from the marketplace can also benefit from the newly minted HSA-eligible status. Putting money into an HSA will save your client on taxes, and those funds can be withdrawn tax free for qualified medical expenses.

Finally, due to tightening restrictions around Medicaid, individuals may lose Medicaid coverage and look to the ACA for a budget-friendly coverage option.

The individual marketplace is always changing for agents and clients alike. We prioritize keeping agents informed and capable to take on challenges in the market with educational resources, top-tier technology, and a diverse library of ACA and ancillary contracts.