Keep Factually independent
Whether you agree or disagree with our analysis, these conversations matter for democracy. We don't take money from political groups - even a $5 donation helps us keep it that way.
How many undocumented immigrants use ACA marketplaces annually?
Executive summary
Available reporting consistently says undocumented immigrants are not eligible to buy Marketplace coverage or receive federal premium tax credits, and therefore standard counts of “ACA Marketplace enrollees” do not include undocumented people [1] [2] [3]. Sources focus instead on lawfully present immigrants (including DACA recipients until August 25, 2025) who have been eligible for Marketplace subsidies and whose eligibility changed in 2025; they do not provide a reliable annual count of undocumented immigrants “using” the Marketplace because federal policy generally bars their enrollment [4] [5] [6].
1. Federal rule: undocumented immigrants are generally excluded from ACA Marketplaces
Federal guidance and multiple expert organizations state that undocumented (unauthorized) immigrants are “generally not eligible” to purchase plans through federal and state ACA exchanges, with or without subsidies, and therefore are not counted as Marketplace enrollees in ordinary statistics [2] [3] [7]. Fact-checking groups reiterate that undocumented people have never had access to premium tax credits and in most cases cannot even buy a plan on HealthCare.gov [1] [8].
2. Why you’ll find few — if any — official counts of undocumented Marketplace use
Because federal law bars most undocumented immigrants from Marketplace purchase or subsidy, federal enrollment data and CBO/KFF analyses do not report an annual number of “undocumented Marketplace users.” Instead, the literature and government analyses focus on lawfully present noncitizens and citizens; the omission is a legal and definitional result, not merely a data gap [2] [3] [9].
3. Confusion arises from changes in law and shifting categories of noncitizens
Recent 2024–2025 policy moves and the 2025 reconciliation law altered which lawfully present groups (for example, some DACA recipients) could access Marketplace subsidies; those changes produced headlines about “immigrants” losing coverage that sometimes mixed up undocumented and lawfully present populations [5] [10] [9]. The Congressional Budget Office and advocates modeled losses among noncitizen enrollees who were lawfully present — e.g., estimates that about 1.2 million noncitizens will lose subsidy eligibility — but that modeling explicitly concerns lawfully present immigrants, not undocumented people [9] [10].
4. State exceptions and non-federal programs complicate the picture
A handful of states have created state-funded or specially approved programs allowing undocumented residents to obtain coverage (for example, Washington, Colorado, and state-run Marketplaces with federal approval), but these are limited, vary by state, and typically do not use federal premium tax credits; such state programs are described in reporting but are not the same as federal Marketplace enrollment numbers [11] [6]. HealthInsurance.org and other explainers note that undocumented people “cannot use the Marketplace unless a state-run Marketplace obtains federal approval” and that when states do create access it’s often without federal subsidies [6] [11].
5. What official estimates do count: lawfully present immigrants affected by 2025 changes
When journalists and analysts give numbers about “immigrants” in the ACA, they generally mean lawfully present immigrants. KFF and the Commonwealth Fund report that the 2025 tax-and-budget law and related rules will make large numbers of lawfully present immigrants ineligible for Marketplace subsidies or Medicaid — with analyses citing figures such as roughly 1.2–1.4 million noncitizens losing eligibility and about 300,000 lawfully present people newly ineligible in the immediate open-enrollment period [10] [5] [12].
6. Bottom line for your original question: no solid annual count exists — because federal policy excludes them
Available sources do not provide an annual count of undocumented immigrants who “use” ACA Marketplaces because federal policy generally prevents their participation; therefore official Marketplace enrollment data and the analytic reports cited here do not report such a number [1] [2] [3]. Where numbers are offered about “immigrants” in the Marketplaces, those numbers refer to lawfully present immigrants whose eligibility has changed due to 2024–2025 rulemaking and legislation [9] [10].
Limitations and alternative viewpoints: advocacy groups emphasize the human impact and note state-level workarounds to extend coverage to undocumented residents [12] [11]; fiscal and policy analyses (CBO/KFF) focus on budget and coverage effects among lawfully present immigrants [9] [10]. If you want, I can compile the specific CBO/KFF estimates and state program examples cited above into a short table or pull the exact sentences that state-by-state programs use to permit noncitizen enrollment.