Which ACA premium tax credits are expiring in 2026 and who will lose them?
Executive summary
The temporary “enhanced” Affordable Care Act (ACA) premium tax credits — the ARPA/IRA-era increases that expanded eligibility above 400% of the federal poverty level (FPL) and reduced required household contributions — are scheduled to expire at the end of 2025 (sunset January 1, 2026) unless Congress acts [1]. If they lapse, millions would face much higher 2026 premiums (KFF estimates average net premium payments could rise 114%, from $888 in 2025 to $1,904 in 2026) and analyses project several million people could lose coverage (estimates cited range from about 3.8 million to 4.8 million) [2] [3].
1. What is expiring and why it matters
The expiring provision is the enhanced premium tax credit (PTC) that was first enlarged by the American Rescue Plan Act and then extended through 2025 by subsequent legislation; the congressional extension set a sunset date of January 1, 2026, returning subsidy rules to the pre‑enhancement (ACA-only) framework unless lawmakers reauthorize the enhancements [1]. The enhancement both raised subsidy amounts and temporarily removed the 400% FPL eligibility cap, making subsidies available to households above 400% FPL; its loss will shrink credits and reimpose the prior income cap for many [4] [5].
2. Who will lose subsidies outright
Households above 400% of the federal poverty level will be the clearest-cut losers: under current law they are eligible in 2025 because of the enhancement but would no longer qualify for any premium tax credit in 2026 if the changes expire [4] [5]. KFF and other analyses highlight that many in this group are older (ages 50–64) and live in high-premium states; those characteristics magnify the financial hit when credits disappear [6].
3. Who will see smaller credits and much bigger premiums
People currently receiving enhanced credits at lower and middle incomes will not all lose eligibility but will see much smaller credits because required contribution percentages will rise; KFF projects average net premium payments could more than double, with median increases driven by both the subsidy reversion and insurers’ expected premium hikes [2] [7]. Examples in the reporting show low- to moderate-income enrollees who paid $0 in 2025 could face nontrivial monthly premiums in 2026, and middle-income families will see large absolute increases [4] [2].
4. Projected scale: millions of people and macro effects
Independent analyses forecast sizable consequences. The Congressional Budget Office estimated roughly 3.8 million more uninsured people annually on average over 2026–2034 if the enhancements lapse, while Urban Institute/Commonwealth Fund work projects up to about 4.8 million people losing coverage in 2026 — figures that industry and policy groups cite when warning of spikes in uncompensated care and economic ripple effects [3] [8]. These projections are offered by different groups using distinct models; the range indicates substantial uncertainty but consistent direction: materially worse affordability and higher uninsurance [3] [8].
5. Insurers’ expectations and premium filings
Insurer rate filings in several states already factor in the subsidy expiration: early filings from Vermont, Oregon, Washington and D.C. include roughly a 4 percentage-point additional premium increase on average attributable to the expected expiration, and some filings attribute several percentage points of a larger overall increase to that policy change [9] [7]. KFF and Peterson‑KFF analysis interpret these filings as an early signal that insurers expect a materially different risk pool and pricing environment if subsidies are not extended [9] [7].
6. Uneven geographic and age-related impacts
The increase in net premium burden will be highly uneven. KFF mapping shows 60‑year‑olds at just over 400% FPL in many states could see their annual net premium more than double or even triple, with especially large dollar increases in states with high underlying premiums such as Wyoming, West Virginia and Alaska [6]. That concentration — older enrollees in higher‑cost markets — explains why the same federal change can produce dramatically different household effects depending on age and where someone lives [6].
7. Political and timing realities
Lawmakers face a tight calendar: insurers are issuing 2026 premium notices and open enrollment is imminent, so Congress would need to act quickly to alter the practical consequences for enrollees and insurers. Debate centers on whether to extend the enhancements, scale them back, or revert fully to ACA-era rules; both fiscal and political tradeoffs are front and center in the reporting [5]. Available sources do not detail any new legislative outcomes after the cited analyses; they describe the policy status quo and projected impacts if Congress does not extend the enhanced credits [1] [5].
Limitations: Projections cited here come from policy groups (KFF, Urban Institute, CBO summaries, insurer filings) that use different methods; they agree on direction but vary in magnitude, and actual 2026 outcomes will depend on insurer behavior, state actions, and any last‑minute federal legislation [2] [3] [9].