ACA Marketplace Enrollment Down in 2026 as Enhanced Tax Credits Expire

Enrollment in the Affordable Care Act (ACA) Marketplaces for 2026 is down by over 1 million people compared to the same time last year, marking the first decline since 2020. This shift coincides with the expiration of enhanced premium tax credits, which previously made coverage more affordable for many enrollees. However, a complete understanding of the impact will require further data analysis over the coming months.

Limitations of Early Enrollment Data

Initial plan selection data, although providing a snapshot of interest in ACA coverage, doesn’t accurately reflect the number of people who ultimately have coverage. This is because plan selection doesn’t account for premium payments. Individuals must submit their first premium payment within 30 days of selecting a plan to activate coverage. Returning, subsidized customers generally have a three-month grace period for nonpayment, extending until March 31, 2026, to catch up on payments before coverage is terminated retroactively.

Approximately 20 million of the current plan selections are from returning customers. In 2025, over four in ten Marketplace enrollees were automatically renewed into their coverage, meaning they didn’t actively re-enroll. Some of these automatically renewed consumers may have disenrolled or stopped making payments upon receiving their first bills for January 2026, potentially skewing preliminary plan selection data.

Timeline for More Complete Enrollment Data

A clearer picture of ACA enrollment will emerge as more data becomes available throughout 2026, and 2027. Key data releases include:

• Effectuated Enrollment: Early Snapshot (July 2026): This report will provide a better understanding of the impact of the expiring tax credits on enrollment than plan selection data alone. It will likely report February 2026 effectuated enrollment as measured on March 15, 2026.
• Effectuated Enrollment: Full Year 2026 (Summer 2027): This data will reflect enrollment after all grace periods have elapsed, providing the most accurate count of covered individuals.
• CMS Risk Adjustment Program State-Specific Data (July 2027): This data will offer a state-by-state look at billable member months in the ACA-compliant individual market, including both on- and off-Marketplace enrollment.
• Issuer Level Enrollment Data (July 2027): Data for HealthCare.gov states will include average monthly effectuated enrollment and average months of enrollment for those who have disenrolled.
• Enrollee-Level External Data Gathering Environment (EDGE) (2028): This dataset will provide enrollment information by metal tier, though it has limitations regarding enrollee demographics and coverage termination data.

Additional Data Sources

Further insights into 2026 enrollment trends may come from:

• Quarterly Earnings Reports (April-May 2026): Insurers may release preliminary enrollment counts during their first-quarter earnings calls.
• Insurer Rate Filings (Summer 2026): These filings offer insight into health cost growth and changes in enrollment.
• National Health Interview Survey (NHIS) (Likely January 2027): Early release data from the NHIS will provide indications of changes in the uninsured rate.

It’s important to note that past effectuation rates may not be reliable indicators for 2026, as this is the first year most ACA Marketplace enrollees will experience a significant increase in premium payments due to the expiration of enhanced tax credits.