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Accounting, Taxes, 1031 Exchanges, Capital Gain Taxes

ACA Open Enrollment 2027: Dates, Subsidies, Tax Rules

ACA open enrollment 2027 runs from November 1, 2026 through January 15, 2027 on HealthCare.gov, and you must sign up by December 15 for coverage that starts January 1. This year matters more than most: the enhanced premium tax credits expired after 2025, benchmark premiums are rising again, and starting with 2026 coverage there is no longer a cap on how much of an overpaid subsidy you may have to pay back at tax time. Here is what changes, how much help you can get, and how to avoid a surprise tax bill.

Key Dates for ACA Open Enrollment 2027

The Centers for Medicare & Medicaid Services (CMS) confirmed the federal marketplace window:

DateWhat happens
November 1, 2026Open enrollment begins on HealthCare.gov
December 15, 2026Last day to enroll for coverage starting January 1, 2027
January 15, 2027Open enrollment ends; coverage starts February 1
January 31, 2027Marketplace must send your Form 1095-A for 2026 coverage

A 2025 federal rule would have ended enrollment on December 15, but a federal court vacated that change in June 2026, according to KFF. The government has appealed, so future years could look different.

If your state runs its own exchange, its dates may differ. Some states close later in January, and a few close earlier. Check your state’s marketplace before you rely on the federal dates.

What Changed for 2027 Coverage

The biggest change is the loss of the extra subsidies that were in place from 2021 through 2025. The IRS explains that Congress only temporarily expanded premium tax credit eligibility for those years. A House-passed extension stalled in the Senate (ASTHO), so the original rules are back.

Here’s what that means in practice:

  • The 400% “subsidy cliff” is back. Households with income above 400% of the federal poverty line generally get no premium tax credit and pay the full premium (IRS).
  • People below the cliff pay a larger share. For 2027, the expected contribution toward a benchmark plan ranges from 2.15% to 10.22% of household income (IRS Rev. Proc. 2026-26), higher than under the enhanced rules.
  • Premiums are up again. KFF reports the average benchmark silver premium is rising 13% for 2027, after about a 26% jump for 2026.
  • Fewer insurer choices in some areas. KFF counts 11 insurers leaving at least one state, including Cigna exiting the individual market in all 11 of its states.
  • Eligibility for some noncitizens narrows. Starting in 2027, only certain lawfully present immigrants, such as green card holders, can receive the credit (CMS guidance).

How the Premium Tax Credit Works in 2027

The premium tax credit is designed to cap what you pay for the second-lowest-cost silver plan in your area (the “benchmark” plan) at a percentage of your household income. The marketplace pays the credit in advance to your insurer, and you reconcile it on your tax return.

For 2027, the IRS set the applicable percentages in Rev. Proc. 2026-26:

Household income (% of poverty line)You pay this share of income for the benchmark plan
Under 133%2.15%
133% to under 150%3.23% to 4.30%
150% to under 200%4.30% to 6.78%
200% to under 250%6.78% to 8.66%
250% to under 300%8.66% to 10.22%
300% to 400%10.22%
Above 400%No credit

Coverage for 2027 uses the 2026 poverty guidelines. According to the Federal Register, the guideline in the 48 contiguous states is $15,960 for one person and $33,000 for a family of four. That puts the 400% cliff at about $63,840 for a single person and $132,000 for a family of four (higher in Alaska and Hawaii).

The same Rev. Proc. sets the 2027 employer-coverage affordability threshold at 10.22% of household income. If your employer offers you affordable, minimum-value coverage, you generally can’t get the marketplace credit.

No More Repayment Cap: Why Your Income Estimate Matters

This is the change most likely to show up on your tax return. Under the 2025 tax law, starting with tax year 2026, “the taxpayer must repay the full amount of any excess advance payments” of the premium tax credit, according to the IRS. In earlier years, lower-income households had a dollar cap on repayment.

That makes your income estimate during ACA open enrollment far more important. If you underestimate income, say because of a raise, a side business, a Roth conversion or a large capital gain, you could owe back the entire excess credit when you file. And if your income ends up just over 400% of the poverty line, you could owe back all of it.

Ways to protect yourself:

  • Estimate high if your income is uncertain. You’ll get any credit you’re owed back as a refund when you file.
  • Report changes during the year. Update the marketplace promptly if your income or household size changes.
  • Watch one-time income. Capital gains, IRA withdrawals and conversions all count toward modified adjusted gross income.
  • Self-employed? Plan ahead. Business income can swing widely. Our post on 2026 self-employment taxes covers how to estimate it.

Reconciling Your Credit With Form 8962

Anyone who received advance payments must file a tax return and attach Form 8962, using the Form 1095-A the marketplace sends by January 31 (IRS). The form compares the credit you were paid in advance with the credit you actually qualify for based on your final income.

  • If you received too little, the difference increases your refund.
  • If you received too much, the difference is added to your tax bill.

Other rules to know: married couples generally must file jointly to claim the credit, and someone who can be claimed as a dependent can’t claim it (IRS).

Smart Tax Moves During Open Enrollment

Your health plan choice and your tax return are more connected than ever. A few strategies to consider:

  • Look at bronze plans with an HSA. Starting in 2026, bronze and catastrophic plans count as HSA-compatible (IRS). HSA contributions lower your modified AGI, which can increase your premium tax credit. See our guide to 2027 HSA contribution limits.
  • Manage income near the 400% line. Pre-tax retirement contributions can keep you below the cliff and preserve thousands in subsidies.
  • Self-employed health insurance deduction. Self-employed people may be able to deduct premiums they pay that aren’t covered by the credit.
  • Turning 65? You’ll move from the marketplace to Medicare. Our Medicare open enrollment 2027 guide covers the costs and timing.

Frequently Asked Questions

When is open enrollment for 2027 health insurance?

On HealthCare.gov, it runs from November 1, 2026 to January 15, 2027. Enroll by December 15 for coverage that starts January 1. State exchanges may have different dates.

Did the ACA subsidies expire for 2027?

The enhanced subsidies expired after 2025. The original premium tax credit still exists for households between 100% and 400% of the federal poverty line, but people generally pay a larger share of income than they did from 2021 through 2025.

What is the income limit for ACA subsidies in 2027?

Generally 400% of the 2026 poverty guidelines: about $63,840 for a single person and $132,000 for a family of four in the 48 contiguous states.

Do I have to pay back my premium tax credit if my income goes up?

Yes. Starting with tax year 2026, there is no repayment cap, so you must repay the full amount of any excess advance credit when you file Form 8962.

Talk to a CPA Before You Pick a Plan

The right plan isn’t only about premiums. Your income estimate, HSA, retirement contributions and any planned conversions or asset sales all affect your credit and your tax bill. If you want help running the numbers before December 15, book a free consultation with Aric.

This article provides information only and should not be construed as advice. It is provided without warranty of any kind.