What do insurers project for premium rate filings in 2026 after the 2025 subsidy shifts?
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Executive summary
Insurers’ 2026 filings show big increases: across the ACA Marketplaces insurers are proposing median gross premium hikes around 18% and average increases as high as 26% (with many filings clustered between ~12%–27%) — and analysts warn that if the temporary enhanced premium tax credits expire, out‑of‑pocket payments for subsidized enrollees could more than double (roughly +114%) in 2026 [1] [2] [3]. Federal regulators project the average post‑credit premium for the lowest‑cost plan on HealthCare.gov will be about $50/month in 2026, up $13 from 2025 — reflecting how tax credits blunt but do not erase insurer rate requests [4].
1. Insurer filings: big ask, but wide variation
Insurers told state regulators they expect materially higher costs next year and filed for steep rate increases: a detailed review of 312 marketplace insurers found a median requested increase of 18% (many filings concentrated between roughly 12% and 27%), while other summaries put the average increase insurers are charging at about 26% nationally — with state‑level spikes above 30% in places [1] [2] [5]. These filings are the backbone of rate projections because they document insurers’ expectations of medical trend, utilization and coverage churn [1].
2. Why insurers say they are raising rates
Across the filings insurers repeatedly cite rising medical costs — hospital, physician and prescription‑drug prices — and an expectation of a sicker risk pool if enhanced subsidies lapse, which would raise gross premiums by insurers’ estimates [1] [6]. Actuarial projections like PwC’s put medical cost trend at 7.5% for the individual market in 2026, reinforcing insurers’ rationale for higher pricing [7].
3. The subsidy shift changes what consumers actually pay
Two separate forces are at work: insurers’ gross premiums are rising significantly, but enhanced premium tax credits enacted in 2021–2025 have been shielding many enrollees. CMS projects that after credits the average lowest‑cost plan on HealthCare.gov will cost eligible enrollees about $50/month in 2026 — up $13 from 2025 — because credits are still expected to cover about 91% of that plan on average in 2026 [4]. Conversely, independent estimates show that if enhanced credits expire, subsidized enrollees’ net premiums would jump far more sharply — KFF estimates average out‑of‑pocket payments would rise by about 114% [3] [2].
4. Enrollment and risk‑pool feedback: insurers price for a sicker population
Insurers explicitly priced in behavioral responses: if subsidies expire, healthier consumers are expected to drop coverage, leaving a smaller, sicker pool and pushing gross premiums higher. KFF and other analysts say insurers added several percentage points to their filings specifically because of that risk‑selection effect [2] [1]. The Congressional Budget Office and market observers likewise expect enrollment declines to raise pre‑subsidy premiums modestly (CBO cited in p2_s1).
5. Geographic and market differences matter
The national averages mask big state and local variation. Some states finalizing rates reported >20% increases; MoneyGeek’s 50‑state analysis found ten states with increases exceeding 30% while others stayed below 10% — tied to local market structure, reinsurance and Medicaid expansion decisions [6] [5]. CMS also notes that issuer participation remains broad in HealthCare.gov states and the average enrollee still has multiple issuer choices, which will influence competitive pressure on final rates [4].
6. Other markets and employers also feel the pressure
Premium pressures are not limited to the ACA individual market. Employers and federal programs are projecting higher costs too: employers expect about a 6–7% rise in employer‑sponsored premiums and Mercer projects total health benefit costs per employee up 6.5% in 2026; federal employee program enrollees face double‑digit contribution increases as well [8] [9] [10]. These parallel trends support insurers’ filings that medical cost pressures are broad‑based [7].
7. Two scenarios for 2026 and what they imply for rate notices
If Congress extends enhanced credits, many subsidized enrollees would see little change in what they pay despite insurers’ higher gross premiums because credits would continue to absorb most of the increase [2] [4]. If credits lapse, analysts project sharp net premium spikes for enrollees (average more than doubling in some estimates) and insurers’ filings already incorporate higher gross prices to reflect the expected enrollment changes [3] [2] [1].
8. Limits of current reporting and what to watch
Available sources document filings, projections and modeling assumptions but do not provide a single definitive national “final” premium figure — states finalize rates at different times and consumer‑level impacts depend on age, income, location and whether Congress acts on subsidies [1] [4] [11]. Watch final state rate approvals, Congress’s subsidy decision, and CMS final Marketplace guidance to see which insurer requests stick and how much consumers ultimately pay [4] [12].
Bottom line: insurer rate filings for 2026 reflect significant upward pressure — median requested increases near 18% and average insurer charges reported around 26% — but the true consumer burden depends heavily on whether enhanced premium tax credits are extended; CMS projects modest net premiums for eligible enrollees after credits ($50/month for the cheapest plan on HealthCare.gov), while KFF and others warn net payments could jump dramatically if credits lapse [1] [2] [4] [3].