What changed
2026 against 2027, line by line
Most year-over-year comparisons in this category are vague. This one is specific, sourced, and honest about which items are settled and which are still in front of a judge.
Money
| 2026 | 2027 | Direction | |
|---|---|---|---|
| Top applicable percentage | 9.96% | 10.22% | Worse |
| Out-of-pocket max, one person | $10,600 | $12,000 | Worse |
| Out-of-pocket max, family | $21,200 | $24,000 | Worse |
| Affordability exemption threshold | 8.05% | 8.5% | Worse |
| Median rate change filed | +20% approved | +15% proposed | Worse |
Poverty levels and the cliff
Subsidies use the prior year’s poverty guidelines. 2026 coverage used the 2025 figures; 2027 coverage uses the 2026 figures, published in January 2026.
| 2026 coverage | 2027 coverage | Direction | |
|---|---|---|---|
| 100% of poverty, one person | $15,650 | $15,960 | Better |
| Each additional person | $5,500 | $5,680 | Better |
| Cliff, one person | $62,600 | $63,840 | Better |
| Cliff, family of four | $128,600 | $132,000 | Better |
Contribution percentages
| Income band | 2026 | 2027 |
|---|---|---|
| Under 133% | 2.10% to 2.10% | 2.15% to 2.15% |
| 133% to 150% | 3.14% to 4.19% | 3.23% to 4.30% |
| 150% to 200% | 4.19% to 6.60% | 4.30% to 6.78% |
| 200% to 250% | 6.60% to 8.44% | 6.78% to 8.66% |
| 250% to 300% | 8.44% to 9.96% | 8.66% to 10.22% |
| 300% to 400% | 9.96% to 9.96% | 10.22% to 10.22% |
Rules and deadlines
| 2026 | 2027 | |
|---|---|---|
| Open enrollment opens | November 1, 2025 | November 1, 2026 |
| Deadline for January 1 | December 15, 2025 | December 15, 2026 |
| Final deadline | January 15, 2026 | January 15, 2027 (under appeal) |
| Monthly low-income special enrollment | Repealed | Permanently gone |
| Excess subsidy repayment caps | Eliminated | Eliminated |
| Enhanced premium tax credits | Expired | Still expired |
Changes that are not currently in effect
Several restrictive rules finalised for 2027 were struck down or enjoined by a federal court in Maryland during 2026, and the government has appealed. As things stand, these are not operating:
| Rule | Status |
|---|---|
| Shortened open enrollment ending December 15 | Vacated, on appeal |
| $5 monthly premium for auto-reenrolled zero-premium enrollees | Not in effect for 2027 |
| Expanded pre-enrollment verification for special enrollment periods | Enjoined |
| Denying advance credits for failure to reconcile | Enjoined |
| Expanded income verification producing extra data-matching issues | Enjoined |
| Bronze plans allowed a 130% out-of-pocket maximum | Enjoined |
| Elimination of standardised plan options | Enjoined |
Changes that are settled
| Rule | Effect for 2027 |
|---|---|
| Monthly special enrollment period at or below 150% of poverty | Permanently repealed by statute |
| DACA recipients | Not eligible for marketplace coverage or subsidies |
| Immigrant eligibility | Narrowed to permanent residents, Cuban-Haitian entrants, and COFA migrants |
| Routine adult dental as an essential health benefit | Prohibited |
| Marketplace user fee | 1.9% of premium on the federal platform |
The short version
You will contribute a slightly larger share of income, your worst-case year costs 13% more, premiums are rising again, and the credit that used to absorb all of that is still gone. Against that, the poverty thresholds moved up a little and several restrictive enrollment rules are not currently operating. Read the enrollment guide for what to do about it, and run your own numbers rather than the averages.
Common questions
Is 2027 better or worse than 2026?
Slightly worse on every axis that can be measured. The share of income you are expected to contribute rose, out-of-pocket maximums rose 13%, and insurers filed another median 15% increase. Poverty guidelines also rose, which nudges the cliff thresholds up and marginally helps people near the edge.
Did anything improve?
The poverty guidelines increased, so the 400% cliff sits about 2% higher in dollar terms, which helps households near the line. Several restrictive 2027 enrollment rules were struck down by a federal court in 2026 and are not currently in effect, which also works in consumers' favour while the appeal is pending.
What is still uncertain for 2027?
The end date of open enrollment, several verification and eligibility rules, and whether Congress restores the enhanced credits. Any of these could change the picture materially before or during open enrollment.
Sources
- 1.IRS Rev. Proc. 2026-26 (2027 applicable percentages)
- 2.IRS Rev. Proc. 2025-25 (2026 applicable percentages)
- 3.CMS 2027 Payment Parameters Guidance
- 4.HHS 2026 Poverty Guidelines, 91 FR 1797
- 5.CMS 2025 Marketplace Integrity and Affordability final rule
- 6.CMS legal statement on the City of Columbus litigation
- 7.CMS 2027 Notice of Benefit and Payment Parameters
- 8.KFF: How the 2025 budget reconciliation law affects the ACA
Marketplace rules change through legislation, rulemaking, and litigation. Confirm anything you are about to act on, or call and ask.
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