Summary
Starting in 2026, the expiration of enhancements – along with policies in the One Big Beautiful Bill Act (OBBBA, P.L. 119-21) and the 2025 Marketplace Integrity and Affordability Final Rule (2025 Final Rule) – will significantly alter major aspects of the Affordable Care Act’s premium tax credits (PTCs). These changes will affect who is eligible for PTCs, who receives them, and the subsidy amounts provided, collectively influencing both the number of people insured through Marketplace coverage and the affordability of Marketplace plans.
In this memo, we present a series of tables highlighting changes to eligibility requirements, eligibility verification, enrollment and re-enrollment, and subsidy amount and their impact on PTCs. Most policies will apply in plan year 2026, with several regulatory changes to eligibility verification and enrollment scheduled to sunset at the end of 2026. Unless otherwise noted, the changes apply to both Federally-facilitated and State-based Exchanges. The memo discusses all major provisions of the 2025 Final Rule, except the provisions prohibiting coverage of specified sex-trait modification procedures (gender-affirming care) as an essential health benefits (effective PY 2026, no sunset) and revisions to standards for terminating agents, brokers, and web-brokers (effective August 25, 2025).