The 2027 Affordable Care Act (ACA) Marketplace open enrollment starts on November 1, 2026, but the period arrives under dramatically different conditions. These shifts result from the expiration of expanded premium tax credits in 2026, new budget legislation, and regulations introduced during the Trump administration that overhauled coverage rules.
Premiums Rise 13% on Average, but Subsidies Fail to Protect All
Insurers proposed a median premium increase of 15% for 2027 plans, though the finalized benchmark silver plan hike averages 13%—the second consecutive year of double-digit rises. States relying on the federal Healthcare.gov platform experienced an 11% increase, while those operating their own exchanges saw 16% hikes. Between 2025 and 2026, Healthcare.gov states faced a 30% spike in benchmark premiums, compared to a 17% rise in state-run markets.
Insurers cite escalating care costs and a deteriorating risk pool following the loss of enhanced tax credits as the primary drivers. The Congressional Budget Office (CBO) estimated that risk pool changes alone contributed about four percentage points on average to premiums in 2026, and insurers expect a similar, additional effect in 2027. While most enrollees still receive subsidies, those earning over 400% of the federal poverty level (FPL) lose all tax credit eligibility and must pay full premiums. Steeper price hikes may drive healthier enrollees to drop coverage, further destabilizing the market.
For the first time since 2014, the ACA’s original subsidy structure has returned, but the transition has already triggered enrollment declines. During the 2026 open enrollment, plan selections dropped by 1.2 million nationwide. By February 2026, effectuated enrollment—those who paid premiums and maintained coverage—fell 12% (2.6 million) to 19.2 million. Broader individual market figures show an 18% decline by June 2026, with enrollment shrinking from 25.2 million to 20.5 million. The CBO now predicts ACA Marketplace enrollment will fall from a 2025 peak of 22.4 million to just 13.1 million by 2027.
States Take Uneven Steps to Fill Gaps
Some states have attempted to mitigate the impact. New Mexico went furthest in 2026, fully backfilling the lost federal assistance for Marketplace enrollees, and is continuing its assistance in 2027. California expanded its state-funded premium assistance to households earning 165% to 200% of FPL, up from the prior cap of 138% to 165%. Other states, including Rhode Island and Virginia, introduced new subsidy programs for 2027. However, these efforts vary-some states provide no additional support.
Insurer Withdrawals Accelerate, Leaving Consumers with Fewer Options
The exodus of insurers has accelerated. By late October 2026, 11 carriers announced exits from at least one state for 2027, while only seven planned new entries. Cigna will leave all 11 states where it currently operates. Shrinking enrollment and higher costs have made the Marketplace less appealing to insurers, leaving some regions with reduced options and weaker provider networks. In areas where competition vanishes, consumers may encounter higher premiums or limited plan choices.
Recent federal actions to address fraud may affect enrollment counts and make it more difficult for enrollees needing brokers’ services in 2027. In September 2026, HHS reported they cancelled coverage for approximately 760,000 individuals who CMS says were “phantom” enrollees, meaning a broker or agent may have signed them up without their knowledge. HHS sent a list of about 1.2 million people to insurers to review. These individuals had been signed up by an agent or broker, had no premium payment and were missing a Social Security number or immigration document that could be verified in real time. If insurers were unable to make contact with these individuals or verify they had incurred claims, CMS cancelled the coverage.
Broker Rules Tighten, Enrollment Aid Dwindles
New regulations for agents and brokers will increase oversight. They can no longer offer cash incentives for enrollments, falsely guarantee zero-cost plans, or mislead about deadlines. HHS has also paused new broker registrations in federally facilitated Marketplaces until February 2027, blocking roughly 19,000 prospective agents. Combined with cuts to Navigator funding, the program training enrollment assistants, the changes may reduce help for consumers dependent on brokers to secure coverage.
The rules remain contested. Litigation has already blocked key provisions, including the removal of repayment limits for excess premium tax credits. Starting in 2026, enrollees face no caps on how much they must repay if their income exceeds projections. The first tax filings under this rule occur in early 2027, leaving consumers uncertain about potential bills. Those near income thresholds, particularly around 250% FPL, may need to adjust health savings account (HSA) or IRA contributions to lower taxable income, though not all can afford to do so.
A change with lasting consequences affects lawfully present immigrants. The 2025 budget law restricts tax credit eligibility to Cuban and Haitian entrants, Compact of Free Association residents, and a few other groups in 2027. Refugees, asylees, and trafficking victims, who previously qualified for subsidies, will now pay full premiums. The CBO projects this will leave one million more uninsured by 2035.
Immigrants and Medicaid Recipients Face New Barriers
Another shift impacts Medicaid enrollees in states with work requirements. Starting in 2027, in states required to implement Medicaid work requirements, consumers who lose or are denied Medicaid coverage solely for not meeting work requirements will also be ineligible for subsidized Marketplace plans in these states. The overlap is small but could include newly unemployed individuals struggling with reporting rules. Without subsidies, they may face unaffordable Marketplace premiums.
The 2027 ACA Marketplace enrollment will also see restrictions on catastrophic plans, which were expanded in 2025 but are now temporarily paused. Under the original 2025 rule, individuals earning too little or too much to qualify for premium tax credits or cost-sharing reductions could enroll in catastrophic plans. These plans offer minimal coverage but are far cheaper. However, a June 2026 court decision in Columbus II reinstated pre-2025 eligibility limits. As a result, only those under age 30, individuals whose premiums exceed 8.5% of their income, or those qualifying for a hardship exemption can now enroll in catastrophic plans for 2027. This limits access for low-income enrollees who previously used these plans as a stepping stone to more full coverage.
Network Adequacy and Gender-Affirming Care Rules Delayed
Court challenges have also halted two other major rule changes for 2027. The first concerns network adequacy standards, which ensure insurers maintain sufficient provider networks. The 2025 rule sought to strengthen these requirements, but litigation has delayed implementation. Without updated standards, consumers in certain regions may encounter provider shortages or uneven access to care, particularly in rural or underserved areas. The second blocked rule would have prohibited states from including gender-affirming care as an essential health benefit under the ACA. Though this restriction has been halted, its revival remains possible if legal challenges fail or new legislation passes.
