As subsidy enhancements’ future remains uncertain, new Marketplace rule and recent legislation bring big shifts for 2026
Healthinsurance.org analysts explain what’s changing – from higher out-of-pocket limits and expanded HSA eligibility to subsidy repayment risks
Minneapolis, MN, Sept. 29, 2025 (GLOBE NEWSWIRE) -- Millions of Americans heading into open enrollment season for ACA Marketplace health coverage will face various changes, under a combination of a new federal rule and the recently enacted One Big Beautiful Bill Act. Together, these policy updates will reshape how some consumers access and pay for health insurance.
The changes come at a time of continued uncertainty over whether enhanced premium subsidies will be extended beyond 2025. These enhancements have been in place since 2021 and resulted in more than 40% of 2025 enrollees paying premiums of no more than $10 a month. According to healthinsurance.org policy analysts, the result is a mix of opportunities and challenges that consumers will need to navigate.
Marketplace open enrollment runs from Nov. 1-Jan. 15 in most states, but consumers should check their state exchanges’ deadlines.
Out-of-pocket limits reach record high
Beginning in 2026, a new federal rule increases the maximum annual out-of-pocket limit for ACA-compliant plans to $10,600 for individual coverage.
“This is a bigger-than-usual year-over-year increase,” said Louise Norris, a health policy analyst with healthinsurance.org. “While many enrollees won’t hit the maximum, those with significant medical spending could be exposed to hundreds of dollars in additional out-of-pocket costs.”
HSA eligibility expands
Some of the changes present new opportunities. The “One Big Beautiful Bill Act” allows people enrolled in bronze or catastrophic Marketplace plans to contribute to health savings accounts (HSAs) starting in 2026. HSAs allow individuals to save pre-tax dollars for medical expenses and are considered one of the most flexible tax-advantaged accounts available.
“For some enrollees, expanded HSA availability could be a real win,” Norris said. “It gives people a way to set aside funds for both short-term and long-term healthcare expenses.”
Subsidy repayment risk grows
The “One Big Beautiful Bill Act” also removes the repayment cap for excess advance premium tax credits (APTC) — subsidies that lower monthly premiums for most Marketplace enrollees. Starting with the 2026 plan year, if a household’s actual income is higher than what was projected at enrollment, there will be no cap on the amount of excess subsidies the policyholder must repay at tax time.
“This change creates a new layer of financial risk,” Norris noted. “Households that underestimate their income could end up owing thousands of dollars. Consumers should take extra care with income estimates and promptly update them with the Marketplace if circumstances change.”
Subsidy access tightens for new immigrants
Another provision of the “One Big Beautiful Bill Act” affects lawfully present recent immigrants with household incomes below the federal poverty level (FPL). Beginning in 2026, they will no longer be eligible for premium subsidies during their first five years in the United States. In prior years, Marketplace rules allowed these consumers to qualify for subsidies since Medicaid is not available to most lawfully present immigrants until they’ve been in the U.S. for five years.
“This rollback could leave some recent immigrants without affordable options, at least for their first five years in the country,” Norris said. “It’s a notable shift from the approach that had been in place.”
Preparing for the future
Taken together, these changes highlight the importance of careful decision making as the Marketplace open enrollment approaches. The uncertainty about subsidy enhancements adds another layer of complexity.
“Consumers should not panic, but they do need to prepare,” Norris advised. “Check income projections carefully, compare all plan choices, and consider whether HSAs are a good fit for your situation. Being proactive will help minimize financial surprises.”
For ongoing updates and consumer-friendly guidance about Marketplace coverage and health reform, visit healthinsurance.org.
Healthinsurance.org provides online resources for consumers about individual and family health insurance. Healthinsurance.org, owned by HealthInsurance.org, LLC, has been providing consumer information about health insurance and health reform for over 25 years
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