Open Enrollment 2026: What's Different This Year
ACA Open Enrollment for 2026 plan year coverage runs November 1, 2025 through December 15, 2025 in most states for January 1, 2026 coverage. (A few state-run exchanges extend later.)
That part isn't new. What is new — or potentially new — is the subsidy structure. The expanded ACA Premium Tax Credits that ran 2021-2025 under the American Rescue Plan and Inflation Reduction Act are scheduled to expire unless Congress extends. That changes the math for a meaningful slice of households.
Here's what to know and how to prepare.
The subsidy change in plain English
For 2021-2025, two changes to ACA subsidies were in effect:
- The "subsidy cliff" at 400% of federal poverty line was removed. Households above 400% FPL could still get subsidies if benchmark premiums exceeded 8.5% of household income.
- Subsidies at lower income bands were enhanced. People at 100-400% FPL got more help than under base ACA rules.
Both of those were temporary. They're scheduled to revert for 2026 plan year unless extended. Check the latest legislative action before assuming anything — this could shift between when this was written and when you enroll.
If the expansion expires:
- Households above 400% FPL likely lose APTC eligibility
- Subsidy curves at lower-to-middle income bands get steeper
- Some households who got help in 2025 will pay more in 2026
If the expansion is extended:
- 2025-equivalent subsidy structure continues
- Math stays roughly the same for most households
Who's most affected if subsidies revert
Self-employed in the $100K–$200K range. Many in this band benefited from the post-2021 expansion. Some will lose subsidies under base ACA rules; some will retain modest help. Run your projected MAGI against the 2026 FPL chart for your household size.
Two-earner households at higher combined incomes. A household combining $130K + $90K of MAGI is well above 400% FPL for a household of 2-3. Likely loses APTC under base rules.
Small business owners. Same logic. Project conservatively.
Lower-income households are not significantly affected — base ACA subsidies in the 100-300% FPL range remain.
What's still the same
- Open Enrollment runs Nov 1–Dec 15 (with state exchange variations)
- Special Enrollment Periods still trigger on qualifying life events (job loss, marriage, birth, Medicaid loss, move, divorce)
- ACA plans still cover the 10 essential health benefits
- Preexisting conditions are still covered from day one
- No medical underwriting questions on ACA plans
- The metal-tier structure (Bronze, Silver, Gold, Platinum) is unchanged
Action items by situation
If you currently have ACA coverage
- Project your 2026 MAGI conservatively
- Compare your subsidy under 2025 rules vs base ACA rules — be ready for either outcome
- During OEP, re-shop. Don't auto-renew without checking. The benchmark plan in your area may have changed, which changes your subsidy and your effective premium.
If you're losing employer coverage
- Inside the 60-day SEP window, ACA is usually the first comparison
- Run subsidies against your projected 2026 MAGI — not last year's W-2
If you're self-employed
- Bring last year's Schedule C and your CPA's projection for 2026
- The self-employed health insurance deduction interacts with ACA subsidy math at tax time. Confirm with your CPA.
- See the Self-Employed Health Insurance page for product comparison
If you're between jobs
- COBRA election window runs separately from ACA SEP
- Run all three numbers (ACA, COBRA, private market) before electing anything
- See the Between Jobs page for the 7-day timeline
What to do in October (the month before OEP)
- Pull your projected 2026 income. Self-employed: get a CPA-projected number. W-2: estimate based on current salary plus expected changes.
- Confirm household size for your tax return. Same as last year, or did anything change (marriage, birth, dependent leaving)?
- List any new medications or health conditions. Affects which plan tier (and which carrier) is the right fit.
- Identify must-keep providers. Specific doctors, hospitals, specialists. Affects which network you need.
- Bring your existing plan documents if you have ACA coverage now. Quick reference for what you currently pay and what you're getting.
That's the prep. Once OEP opens, the actual enrollment takes 30-60 minutes including the conversation with a broker.
Why we suggest enrolling early in OEP
December 15 is a hard deadline for January 1 coverage in most states. Two reasons to not wait until December 14:
- Marketplace tech load. The healthcare.gov website slows dramatically in early-mid December as procrastinators land. Enrolling Nov 1-15 or Nov 25-Dec 5 is faster.
- Time to fix mistakes. If your initial enrollment has an error (income misreporting, household size wrong, plan you didn't intend to pick), there's time to correct before the deadline.
If you wait until December 13, the first error is harder to recover from before January 1.
Common ACA mistakes we see
Reporting last year's W-2 instead of projected income. APTC is calculated on projected MAGI for the year you're enrolling. Use your real 2026 number, not last year's tax return.
Forgetting to update mid-year. Income changes, household changes, address changes. Update the marketplace when life changes — protects against tax-time clawback.
Auto-renewing without checking. The benchmark plan in your area can change year-over-year, which changes both your subsidy and your effective premium. Always re-shop during OEP.
Picking Bronze when Silver with CSRs is cheaper. At certain income levels, Silver-tier plans with Cost-Sharing Reductions can have lower out-of-pocket costs than Bronze plans for the same monthly premium. Run both options.
Missing Special Enrollment Period after a qualifying event. 60 days from the qualifying event. Calendar it. Don't lose it.
For more on ACA fundamentals, see the ACA Marketplace service page.
FAQ (FAQPage schema)
Q · When is ACA Open Enrollment 2026?
November 1, 2025 through December 15, 2025 in most states for January 1, 2026 coverage. A few state-run exchanges extend later — check your specific state.
Q · Will my ACA subsidy change in 2026?
Possibly. The expanded subsidies that ran 2021-2025 are scheduled to expire for 2026 unless Congress extends. Check current legislative status; if the expansion expires, households above 400% FPL likely lose subsidy eligibility under base ACA rules.
Q · What happens if I miss Open Enrollment?
You're out of ACA Marketplace until the next OEP, unless a qualifying life event opens a Special Enrollment Period (job loss, marriage, birth, Medicaid loss, move). Private-market plans are available year-round with no enrollment window.