Will insurer premiums rise or fall in 2026 because of 2025 subsidy policy shifts?

Checked on December 5, 2025
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Executive summary

Insurers’ filed rates and expert analyses show pre-subsidy premiums for ACA marketplace plans are set to rise sharply in 2026 — analyses report median proposed increases of about 18% and headline projections averaging ~26% in 2026 — and policymakers’ handling of enhanced premium tax credits will determine whether consumers actually pay far more at the register (KFF/Peterson-KFF/Commonwealth Fund) [1] [2] [3]. Multiple nonpartisan groups estimate that if enhanced subsidies expire, monthly out‑of‑pocket premiums for subsidized enrollees could more than double (KFF/CMS/Commonwealth Fund) [4] [5] [6].

1. What insurers are filing: big rate requests driven by medical‑cost trends

Insurer rate filings for 2026 show unusually large proposed increases: a median proposed premium hike around 18% across hundreds of marketplace plans and many filings citing an underlying assumed medical cost trend of roughly 7–8% as a core driver (Peterson‑KFF; Commonwealth Fund) [1] [3]. Filings and summaries from dozens of states show some insurers proposing increases above 20% in specific markets, and analysts say this is the largest set of rate increases since 2018 [1] [3].

2. The headline 26% number and why it matters (but isn’t the whole story)

KFF and follow‑on reporting put the “amount insurers charge” for benchmark marketplace plans up about 26% on average in 2026 — that figure captures gross premiums insurers list, not what subsidized enrollees will owe after credits [2] [7]. That 26% is a market‑wide average reflecting higher list prices; it is useful to gauge insurer pricing decisions but doesn’t directly translate to every consumer’s monthly bill if subsidies remain in force [2].

3. The subsidy cliff: how policy shifts amplify (or blunt) consumer pain

The temporary “enhanced” premium tax credits enacted in ARPA/extended by IRA through 2025 reduced out‑of‑pocket costs and expanded eligibility; many analyses show the political question of extending those enhancements is the pivot on 2026 affordability. Nonpartisan estimates find that if the enhancements expire, average annual premiums paid by subsidized enrollees could jump from about $888 in 2025 to roughly $1,904 in 2026 — an increase of roughly 114% — and CBO and other models forecast enrollment declines and higher uninsured counts (KFF; Harvard Kennedy School; CBO summaries) [4] [6] [8].

4. Two separate effects: insurer pricing versus enrollee pocketbook

Analysts separate “gross” premium changes (what insurers charge) from “net” premium payments (what enrollees pay after tax credits). Insurers say policy uncertainty — including the expectation that some healthier people may drop coverage if subsidies lapse — pushed them to up list prices by several percentage points (Peterson‑KFF; KFF) [1] [2]. But whether enrollees actually face doubling of bills depends squarely on Congress and administration decisions about the credits [2] [4].

5. Small‑group, employer, Medicare and federal plans: rising costs are broader than marketplaces

The marketplace isn’t the only arena seeing higher premiums. Small‑group insurers proposed median increases of about 11% for 2026, employer‑sponsored plans are expected to rise roughly 6–7% (or higher in some analyses), and federal employee health benefits are facing double‑digit average increases (11–12%); Medicare premiums and Parts A/B changes also push beneficiaries’ costs up in 2026 [9] [10] [11] [12]. These separate trends reflect underlying medical inflation, drug costs, and administrative decisions [1] [13].

6. What to watch next — policy deadlines and practical choices

Two decisive levers will shape consumer outcomes: whether Congress or the Administration extends enhanced premium tax credits beyond 2025, and insurer finalized rates and state regulator approvals that may moderate initial filings [14] [15] [1]. If credits are extended promptly, many subsidized enrollees would see much smaller bill changes despite higher listed premiums; if not, net premiums for those receiving credits are predicted to surge [2] [4].

7. Competing narratives and embedded agendas in reporting

Policy think tanks and advocates emphasize the human‑cost risks of letting enhanced credits lapse — higher premiums, coverage losses, more uncompensated care — while some budget‑focused analysts stress federal spending implications and long‑run fiscal tradeoffs (Center for Budget and Policy Priorities; Conference Board; CRFB) [16] [14] [15]. Media headlines highlighting “26%” or “double your premium” reflect different emphases: gross insurer price changes versus subsidized enrollee pocketbooks [2] [7].

Limitations: available sources document insurer filings, KFF/CBO estimates, and agency fact sheets through late 2025 but do not report a final congressional action extending or ending the enhanced subsidies as of these sources; they also show preliminary filings that may be revised before final rates [1] [5] [4].

Want to dive deeper?
How did 2025 subsidy policy changes alter insurer risk pools and enrollment numbers?
What do insurers project for premium rate filings in 2026 after the 2025 subsidy shifts?
How will state-level actions and reinsurance programs respond to 2025 federal subsidy changes?
Which demographic groups are most affected by 2025 subsidy shifts and how will that influence 2026 premiums?
What role will insurer competition and market exits/entries play in 2026 premium levels?