Enrollment
ACA subsidy changes for 2027: what agents need to know
By the QuoteDeck team · Updated · 2 min read
The short answer
The enhanced premium tax credits that removed the 400% of poverty limit covered tax years 2021 through 2025. For later years, the premium tax credit is generally limited to households between 100% and 400% of the federal poverty line, and there is no cap on repaying excess advance credits. Clients near or above 400% need an accurate income estimate before they enroll.
What changed after 2025
| Tax years 2021 to 2025 | Tax years after 2025 | |
|---|---|---|
| Income eligibility | No 400% of poverty upper limit | Generally 100% to 400% of the federal poverty line |
| Repaying excess advance credits | Repayment was capped for many households | No repayment cap. Excess advance credits are repaid in full |
HealthCare.gov posts 2027 income levels and savings on November 1. Until then it suggests using 2026 amounts to estimate 2027 savings. Check it after November 1, and check for any change in the law before you quote.
Which clients this affects most
- Households above 400% of the poverty line, who generally no longer qualify for the premium tax credit and will see the full premium.
- Households near 400%, where a raise, a bonus or self-employment income can push them over the limit and require them to repay all advance credits.
- Clients with income that changes during the year, such as commission, seasonal or self-employment income.
- Older clients, whose unsubsidized premiums are highest.
Agent checklist for Open Enrollment
- Re-check every renewing client’s income estimate for 2027. Savings are based on the income estimate for the year of coverage, not last year.
- Flag clients close to 400% of the poverty line and explain that going over means repaying all advance credits at tax time.
- Tell clients to report income changes during the year so their advance credits can be adjusted.
- Show the premium after subsidy for each option, and for clients over the limit, show lower-premium options next to the plan they have now.
- Pair a lower-premium plan with hospital indemnity or accident coverage when a client is moving to a higher deductible.
Estimate a client’s premium tax credit with the free ACA subsidy calculator
Check how close a client is to the 400% limit with the free federal poverty level calculator
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Frequently asked questions
Did the enhanced ACA subsidies expire?
Yes. According to the IRS, Congress removed the 400% of poverty limit only for tax years 2021 through 2025. For later years the premium tax credit is generally limited to households from 100% to 400% of the federal poverty line.
Is there a cap on repaying ACA subsidies for 2026 and later?
No. The IRS says there is no repayment cap for tax years after 2025, so excess advance credit payments must be repaid in full.
When are 2027 ACA savings amounts available?
HealthCare.gov says 2027 income levels and savings are posted November 1. Before then, it suggests estimating with 2026 amounts.
Sources
Checked on October 16, 2026. Rules change, so confirm with the source and your carriers.
This guide is general information for licensed insurance professionals, not legal or compliance advice. Follow CMS, state and carrier requirements that apply to you.
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