The Affordable Care Act (ACA) Marketplace 2027 Open Enrollment period starts November 1, 2026, in most states. The expiration of enhanced premium tax credits in 2026 triggered changes under the 2025 budget reconciliation law, altering coverage trends in the Marketplace. Additional modifications are again expected in 2027.
There are nine key things to know for the 2027 Open Enrollment period. First, premiums are going up by double-digits, but most people get a subsidy. The average increase in finalized benchmark silver premiums for 2027 is 13%, marking a second consecutive year of double-digit proposed increases.
In states that use the Healthcare.gov platform, benchmark silver premiums are increasing 11%, whereas states that run their own enrollment platforms are seeing premium increases of 16%. Insurers point to a higher-than-usual increase in the underlying cost of care as a factor contributing to higher premiums.
ACA Marketplace insurers also cite the expiration of the enhanced premium tax credits and the resulting changes in the risk pool as factors contributing to higher premiums. Most enrollees get a subsidy that will cushion the impact of these increases in 2027. However, people with incomes above 400% of the federal poverty level (FPL) will be particularly hard hit because they no longer qualify for premium tax credits and must pay the full cost of coverage.
Marketplace Enrollment Declines
Second, Marketplace enrollment is declining following the expiration of enhanced premium tax credits, and may continue to fall for other reasons. During the 2026 Open Enrollment Period, Marketplace plan selections fell by 1.2 million from 2025.
By February 2026, effectuated Marketplace enrollment was down 12% (or 2.6 million people) from the previous year to 19.2 million people. More recent Marketplace-specific enrollment data are not yet available, but enrollment data for the individual market suggest the decline may have continued through the first half of 2026.
The number of insurers participating in the ACA Marketplaces is expected to decrease again in 2027, with more insurers announcing plans to exit the Marketplace than to enter. As of October 29, 2026, 11 carriers had announced plans to exit at least one state for 2027, while seven carriers had announced plans to enter a new state.
Some states that operate their own Exchanges are using state-funded subsidies to help offset the expiration of the enhanced premium tax credits. New Mexico, for example, is continuing its assistance in 2027, having fully backfilled the lost federal assistance for Marketplace enrollees in 2026.
Recent federal actions to address fraud may affect enrollment counts and make it more difficult for enrollees needing brokers’ services in 2027. In September 2026, HHS reported they cancelled coverage for approximately 760,000 individuals who CMS says were “phantom” enrollees, meaning a broker or agent may have signed them up without their knowledge.
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Eligibility Changes Ahead
Changes in the ACA Marketplaces will affect eligibility for tax credits. the 2025 budget reconciliation law limits eligibility for tax credits in the Marketplace to only certain groups of lawfully present immigrants including 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
Other lawfully present immigrants, such as refugees, victims of human trafficking, and asylees, can still purchase Marketplace coverage but will no longer be eligible for premium tax credits. Without subsidies, many may be unable to afford their premiums and could drop coverage.
In its latest projections, the Congressional Budget Office (CBO) estimated ACA Marketplace enrollment would fall from a peak of 22.4 million in 2025 to 13.1 million in 2027.
Starting in 2027, in states required to implement Medicaid work requirements, consumers who lose or are denied Medicaid coverage solely for not meeting work requirements will also be ineligible for subsidized Marketplace plans in these states. This may include individuals who recently lost a job and who would likely not meet the Medicaid work requirements.
Litigation Impacts Marketplace
Litigation challenging two final regulations that make substantial changes to Marketplace requirements – the 2025 program integrity rule and the HHS Notice of Benefit and Payment Parameters for 2027 – have halted implementation of many new rules for the time being. The state of play after several court decisions over the past year includes the failure to reconcile requirement, which will not disqualify consumers from receiving premium tax credits if they fail to file and reconcile prior years’ premium tax credits.
This expanded eligibility has been temporarily paused due to a June decision in Columbus II. This means only a narrow group of people including individuals under age 30, those whose Marketplace or employer coverage would cost more than 8.5% of their income, and those who qualify for a hardship exemption can enroll in these plans during open enrollment. Other requirements are not in place for now or have been vacated.
As a result of these changes, enrollees will face the elimination of repayment limits, and consumers who are denied or removed from Medicaid coverage for not meeting work requirements will be ineligible for premium tax credits. The impact of these changes on the ACA Marketplace and its enrollees remains to be seen, with the 2027 Open Enrollment period set to begin on November 1, 2026, and the national average lowest-cost silver premium in 2027 corrected to $681.
Other states provided more limited assistance in 2026 and may expand eligibility in 2027. California, for example, is continuing state-funded premium subsidies but is expanding its program to partially backfill lost enhanced tax credits for households with incomes between 165% and 200% FPL.
