ACA Open Enrollment 2027 — Deadlines and Premium Tax Credit Changes
HealthCare.gov open enrollment for 2027 runs Nov 1, 2026 to Jan 15, 2027 (Dec 15 for a Jan 1 start). What changes for the premium tax credit under the 2025 tax law, with dates checked against IRS, CMS, and HealthCare.gov. No repayment cap from 2026, citizenship and immigration limits from 2027, and new checks before enrollment from 2028.
By Greg, Editor at Finance Maxx. Published · Updated
ACA Marketplace open enrollment for 2027 coverage on HealthCare.gov runs November 1, 2026 – January 15, 2027. Enroll by December 15, 2026 for coverage that starts January 1, 2027. This is also the first open enrollment where several premium tax credit changes from the 2025 tax law (Pub. L. 119-21, often called the One Big Beautiful Bill Act) start to hit: no cap on paying back excess advance credits on 2026 returns, citizenship and immigration limits from 2027, and new checks before enrollment from 2028.
Official sources: CMS statement on City of Columbus v. Kennedy (July 31, 2026) and failure-to-reconcile statement (July 27, 2026), HealthCare.gov dates and deadlines and keep or change your plan, IRS IR-2026-121, the proposed regulations REG-101576-26 (91 FR 65494), IRS premium tax credit Q&A, Rev. Proc. 2026-26, and the CMS plan year 2027 noncitizen APTC and CSR guidance.
The short version
| Question | Short answer |
|---|---|
| Open enrollment (HealthCare.gov) | Nov 1, 2026 – Jan 15, 2027 |
| Deadline for a Jan 1 start | Dec 15, 2026 |
| Enroll Dec 16 – Jan 15 | Coverage starts Feb 1, 2027 |
| Pandemic-era extra savings | Ended Dec 31, 2025 |
| Income range for the credit | Generally 100%–400% of the poverty line |
| Repayment cap on excess APTC | Gone from tax year 2026 |
| Credit limited by immigration status | From tax year 2027 |
| Checks before advance credit is paid | From tax year 2028 |
| Status of IRS rules | Proposed; comments due Nov 30, 2026 |
2027 open enrollment dates
| Date | What happens |
|---|---|
| Nov 1, 2026 | Open enrollment starts on HealthCare.gov |
| Dec 15, 2026 | Last day to enroll or change plans for a Jan 1 start |
| Dec 16 – Jan 15 | Plans picked now start Feb 1, 2027 |
| Jan 15, 2027 | Open enrollment ends |
| Jan 2028 | Form 1095-A for 2027 coverage arrives |
A 2025 rule would have ended federal open enrollment by December 31 starting with 2027 coverage. After the court rulings in City of Columbus v. Kennedy, CMS said it has not changed the open enrollment dates and that the federal Marketplace runs through January 15, 2027. If you see a Dec. 15 or Dec. 31 end date elsewhere, that’s the Jan. 1 start deadline or the old rule, not the end of open enrollment.
State marketplaces: if your state runs its own exchange, it can set different dates. Check your state marketplace’s own site for its dates.
What changed for the premium tax credit, by year
The premium tax credit (PTC) helps pay Marketplace premiums. Most people take it in advance (APTC) and settle up on Form 8962 at tax time. Here’s what the 2025 law changed and when each change starts, per the IRS proposed rules.
| Change | Starts |
|---|---|
| Full repayment of excess APTC (no cap) | Tax year 2026 |
| No PTC under 100% FPL for people barred from Medicaid by immigration status | Tax year 2026 |
| No PTC for plans picked through an income-based special enrollment period | Plan years 2026+ |
| PTC only for citizens, nationals, and listed noncitizens | Tax year 2027 |
| Denied Medicaid for not meeting work rules → no PTC | 2027 (proposed IRS rule) |
| Income and status checks before APTC; filing-and-reconcile test in the law | Tax year 2028 |
1. No more repayment cap (2026 returns onward)
Before, if your income came in higher than you estimated, a cap could limit how much extra advance credit you had to pay back. The law removed those caps for tax years beginning after December 31, 2025. The IRS says that for tax years after 2025 you repay the full amount by which your advance credit exceeds the credit you qualify for. It comes out of your refund or adds to what you owe.
That first hits 2026 returns filed in early 2027, and every year after. Treasury estimates about 3.7 million returns in 2028 will include a repayment. The practical fix is a realistic income estimate, and updating HealthCare.gov when your income changes mid-year.
2. Citizenship and immigration limits (2027)
For tax years beginning after December 31, 2026, the credit is limited to:
- U.S. citizens and U.S. nationals
- Lawful permanent residents (green card holders)
- Certain Cuban and Haitian entrants
- People living in the U.S. under a Compact of Free Association (COFA)
Other lawfully present noncitizens can still enroll in a Marketplace plan but won’t get APTC or cost-sharing reductions for 2027. IRS IR-2026-121 says HHS expects to issue matching rules.
On HealthCare.gov, CMS says noncitizens will be asked to attest to their status, the Marketplace checks it with DHS, and people who can’t be verified get 95 days to send documents (like a green card) while keeping their advance credit. Enrollees who don’t update their application by December 15 and can’t be verified will be re-enrolled without financial help from January 1, 2027, or removed if they aren’t lawfully present. CMS says affected enrollees get a notice with appeal rights. You can cancel the plan if you don’t want it at full price. CMS also says people losing APTC this way don’t get the 3-month grace period for unpaid premiums.
3. Below 100% of the poverty line (2026)
Lawfully present people with household income under 100% of the poverty line could get the credit if their immigration status barred them from Medicaid. Starting with tax year 2026, they no longer qualify.
4. Income-based special enrollment periods (2026 plan years)
The law denies the credit for months of coverage chosen through a special enrollment period that’s based only on income (like the low-income enrollment period HealthCare.gov offered in recent years). Life-event enrollment periods, such as losing other coverage, moving, or having a baby, are not affected by this rule.
5. Medicaid work rules (2027, proposed)
The law requires states to apply Medicaid community engagement rules (generally 80 hours a month of work, school, or service) by January 1, 2027, though states can get exemptions to the end of 2028. Under the proposed IRS rules, someone denied Medicaid only for not meeting those rules is treated as eligible for Medicaid, so they can’t get the premium tax credit either.
6. Pre-enrollment checks (2028, not 2027)
The law also requires Marketplaces to verify income, household size, other coverage, address, and immigration status before paying advance credits. That applies to tax years beginning after December 31, 2027, so it starts with 2028 coverage, not 2027. Some articles lump it in with the 2027 changes; the IRS proposed rules put it in 2028. HHS published its own proposed rule on pre-enrollment verification on October 27, 2026 for plan year 2028, with verification starting August 1, 2027. Comments on that rule are due November 27, 2026.
The 2027 credit math
Your credit is generally the price of the second-lowest-cost silver plan in your area minus an expected contribution that’s a share of your household income (IRS Q&A, Q24). For 2027, Rev. Proc. 2026-26 sets that share:
| Household income (% of poverty line) | You pay |
|---|---|
| Under 133% | 2.15% |
| 133% – 150% | 3.23% → 4.3% |
| 150% – 200% | 4.3% → 6.78% |
| 200% – 250% | 6.78% → 8.66% |
| 250% – 300% | 8.66% → 10.22% |
| 300% – 400% | 10.22% |
The percentage rises across each band. Above 400% there’s generally no credit, because the temporary rule that let higher incomes qualify covered only 2021 through 2025 (IRS Q&A, Q7).
The 2027 credit uses the poverty guidelines published as of the start of open enrollment, which are the 2026 HHS guidelines. For the 48 contiguous states and D.C.:
| Household size | 100% | 400% |
|---|---|---|
| 1 | $15,960 | $63,840 |
| 2 | $21,640 | $86,560 |
| 4 | $33,000 | $132,000 |
Alaska and Hawaii have higher guidelines. Household income here means modified AGI for you, your spouse if filing jointly, and dependents who must file.
Form 8962 reconciliation
- Your Marketplace sends Form 1095-A (for 2027 coverage, in January 2028).
- You file Form 8962 with your federal return. This is required whenever any APTC was paid, even if you otherwise wouldn’t file.
- If your actual credit is more than the advance payments, you get the difference.
- If it’s less, you repay the full excess (no cap from 2026 on).
Failure to reconcile in 2027: a court stay blocks Marketplaces from removing or denying 2027 APTC because you didn’t file and reconcile for a past year (CMS, July 27 and 31, 2026). CMS says the law still requires you to file and reconcile, and the 2025 law adds a filing-and-reconcile test starting in 2028. File anyway.
If you can’t pay a repayment balance, the IRS says it works with taxpayers on payment plans like any other tax balance (IRS Q&A, Q32).
What to update by December 15
- Read your notices. HealthCare.gov says your insurer and the Marketplace send letters by November 1 about 2027 prices and savings.
- Update expected 2027 income and household on HealthCare.gov. Savings are based on your expected income; with no repayment cap, a low guess costs more at tax time.
- Compare plans. If you don’t act by Dec. 15, you may be auto re-enrolled in the same or a similar plan, but the price and savings can change.
- Noncitizen enrollees: answer any status notice and upload documents. If you’re no longer eligible for APTC, decide whether to keep the plan at full price.
- Considering an HSA? For months after 2025, the law treats Marketplace bronze and catastrophic plans as HSA-compatible. See 2027 HSA contribution limits and check your room in the HSA calculator.
- Budget the full premium. Plug your net monthly premium into the budget calculator and check your pay against it with take-home pay and FICA.
Proposed rules: comment period and hearing
The IRS proposed rules (REG-101576-26) were published October 15, 2026. Written comments are due November 30, 2026 at regulations.gov. A phone hearing is set for December 8, 2026, at 10 a.m. ET. It’s cancelled if no outlines from speakers arrive by Nov. 30.
| Item | Status |
|---|---|
| Repayment cap removal, immigration limits, SEP rule, 2028 checks | In the statute (final law) |
| How the IRS applies them (Form 8962, 1095-A, Medicaid work-rule tie-in) | Proposed regulations |
| HealthCare.gov 2027 dates, status checks, auto re-enrollment without APTC | CMS guidance |
| HHS pre-enrollment verification rule (2028 coverage) | Proposed Oct. 27, 2026 |
| HHS rules matching the immigration limits | Expected, not yet issued |
What this does not do
- It’s not personalized tax, legal, or immigration advice. Confirm your status questions with the Marketplace (1-800-318-2596, TTY 1-855-889-4325) or a qualified professional.
- It doesn’t list each state marketplace’s dates or rules.
- It doesn’t estimate 2027 premiums or your credit amount. The federal tax calculator doesn’t model the premium tax credit.
- It reflects the law, proposed IRS rules, and CMS guidance as of October 27, 2026. Court rulings and final rules may change the details.
Related reading
- Medicare Open Enrollment 2026: Oct 15–Dec 7, a separate program for people on Medicare
- 2027 HSA contribution limits: $4,500 / $9,000, plus bronze and catastrophic plan HSA rules
- Take-home pay and FICA: what’s left from each paycheck before premiums
- The 50/30/20 budget guideline: where a health premium fits in a monthly budget
- How this federal tax estimate is built: what the calculator does and doesn’t model
- This year: tax: 2025 and 2026 brackets and standard deductions
This page summarizes the law, proposed IRS rules, and CMS guidance as of October 27, 2026. Check HealthCare.gov or your state marketplace before you enroll, because dates and rules can change.