How do 2026 FPL thresholds compare to 2025—what are the percentage increases and reasons for changes?
Executive summary
The key numeric changes for 2026 center on the ACA “affordability” percentage rising from 9.02% in 2025 to 9.96% for 2026 plan years, which raises the FPL‑based safe‑harbor monthly employee contribution from about $113.20 to $129.90 using the 2025 FPL of $15,650 (mainland U.S.) [1] [2]. Policy changes reinstating the traditional 100%–400% FPL subsidy range for 2026 (absent congressional action extending ARP/IRA enhancements) mean many subsidy and eligibility calculations for 2026 will rely on the 2025 HHS poverty guidelines ($15,650 for an individual in 2025) [3] [4] [5] [6].
1. What changed numerically and why it matters: the affordability percentage jump
The IRS set the ACA employer “affordability” safe‑harbor percentage at 9.96% for plan years beginning in 2026, up from 9.02% in 2025; using the 2025 FPL of $15,650 this yields a monthly safe‑harbor maximum employee contribution of about $129.90 (up from roughly $113.20 in 2025) [1] [7] [2]. That numeric uptick directly affects whether employer plans meet the employer mandate’s affordability test under the FPL safe harbor and therefore whether employees can claim Marketplace premium tax credits [1] [7].
2. Which poverty figures are used for 2026 coverage calculations
Coverage year 2026 eligibility and many Marketplace calculations are based on the 2025 HHS poverty guidelines because subsidies and thresholds use the prior year’s guidelines; the 2025 guideline for a single person in the contiguous U.S. is $15,650 and higher amounts apply for Alaska and Hawaii [3] [6] [4]. Multiple sources note that the FPL figures are issued by HHS annually (typically January) and that coverage decisions for 2026 therefore reference the 2025 poverty guidelines until HHS issues 2026 guidelines [4] [8].
3. Why 2026 percentages look higher than 2025 for consumers
Several reference charts and guidance point out that 2026 percentage schedules (for example, premium contribution percentages tied to income) will be higher than 2025 because the temporary subsidy enhancements enacted in the American Rescue Plan and extended by the Inflation Reduction Act are set to expire at the end of 2025 unless Congress acts [3] [4]. As a result, the subsidy slope and eligibility bands revert toward pre‑ARP norms (e.g., the conventional 100%–400% FPL premium credit range returns under current law for 2026 coverage) increasing the apparent percentage burden on many households [4] [5].
4. How employers and non‑calendar plans can respond (practical consequences)
Employers that rely on the FPL safe harbor should recheck contribution formulas because a higher affordability percentage and a likely higher 2026 FPL (HHS poverty guidelines typically rise with inflation) will produce a larger allowable employee premium under the safe harbor; non‑calendar‑year plans may be permitted to use the FPL in effect within six months before plan year start, so timing affects whether a plan uses 2025 or the new 2026 FPL for calculations [1] [7]. Advisories note that many plans benefit from waiting for the 2026 FPL because it “will almost certainly exceed” 2025 levels, producing an even higher safe‑harbor contribution threshold [1].
5. Where sources agree and where uncertainty remains
Sources consistently report the IRS affordability percentage increase to 9.96% for 2026 and the use of 2025 poverty guidelines for 2026 coverage calculations [1] [7] [3]. They also agree the temporary subsidy expansions run through 2025 and without further legislation the traditional 100%–400% FPL subsidy limits return in 2026 [4] [5]. Available sources do not mention the finalized 2026 HHS poverty guideline numbers themselves (the absolute 2026 FPL figures are not in these documents), so exact percent changes in the FPL year‑over‑year beyond examples and expectations are not reported in the provided material [8] [3].
6. Bottom line for households and policy watchers
Households should expect higher nominal contribution percentages and a reversion to the pre‑ARP subsidy architecture in 2026 unless Congress intervenes; employers should recalculate affordability under the new 9.96% figure and watch the official HHS 2026 poverty guidelines when released [1] [4] [7]. Analysts and advocates will frame these numeric shifts differently: employer‑side commentary highlights the compliance breathing room from a higher safe‑harbor contribution, while consumer advocates stress that expiration of ARP/IRA enhancements will likely reduce net subsidy support for many families [1] [4] [5].