What are the deadlines for ACA reporting?

The Affordable Care Act (ACA) affordability threshold for plan years beginning in 2026 is 9.96% of an employee's household income (or applicable safe harbor wages). This is an increase from the 2025 rate of 9.02%.

Overview of 2026 Affordability

• Percentage Limit: The employee's required monthly contribution for the lowest-cost, self-only coverage option providing minimum value cannot exceed 9.96% of their income.
• Comparison: This marks an increase from 2025 (9.02%) and gives employers more flexibility regarding employee premium contributions.

Employer Safe Harbors for 2026

To avoid calculating individual household incomes, employers can use one of three IRS IRS Announces 2026 ACA Affordability Indexed Amount safe harbors:

• Form W-2 Safe Harbor: Monthly self-only contribution is ≤ 9.96% of Box 1 W-2 wages.
• Rate of Pay Safe Harbor: Monthly self-only contribution is ≤ 9.96% of computed monthly wages (hourly rate × 130 hours, or monthly salary).
• Federal Poverty Line (FPL) Safe Harbor: Monthly self-only contribution is ≤ 9.96% of the applicable Federal Poverty Line amount. For the mainland U.S., this generally caps the lowest-cost monthly employee contribution around $129.89 (depending on exact FPL updates).

ACA reporting codes required for Form 1095-C are categorized into Series 1 (Line 14) to describe the offer of coverage and Series 2 (Line 16) to explain safe harbors and enrollment status.

Line 14 Codes (Offer of Coverage)

Line 14 codes tell the IRS what type of health coverage, if any, was offered to an employee, their spouse, and their dependents.

• 1A: Qualifying Offer (Minimum Essential Coverage and Minimum Value offered to the employee, plus affordable coverage for spouse and dependents).
• 1B - 1E: Various combinations of coverage offers to the employee, spouse, or dependents only.
• 1F: Minimum Essential Coverage offered that was not Minimum Value.
• 1G: Offer of coverage to a non-employee (such as a former employee on COBRA) for some or all of the year.
• 1H - 1J / 1K: No offer of coverage, or specialized ICHRA (Individual Coverage Health Reimbursement Arrangement) offers.

Line 2 Series Codes (Safe Harbors & Exceptions)

Line 16 codes explain why an employee was not enrolled or indicate an affordability safe harbor.

• 2A: Employee not employed during the month.
• 2B: Employee not a full-time employee.
• 2C: Employee enrolled in the coverage offered.
• 2F, 2G, 2H: Section 4980H affordability safe harbors (W-2, Federal Poverty Line, and Rate of Pay methods).
• 2I: Non-assessment period for multiemployer plan interim rule relief.

For a full reference list and guidance, check out the ACA 1095-C Codes Cheat Sheet and the detailed breakdown on the ACAwise Services Guide.

In 2026, the Affordable Care Act (ACA) marketplace is facing higher premiums, record-high deductibles, and lower enrollment following the expiration of pandemic-era enhanced premium tax credits at the end of 2025.

Expiration of Enhanced Subsidies and Costs

• Higher Premiums and Deductibles: According to KFF, average monthly net premium payments rose by 58%, and average marketplace deductibles jumped by 37% to a record high of $3,786 as many enrollees shifted to cheaper bronze-tier plans.
• Enrollment Decline: National effectuated enrollment fell by roughly 12% to 19.2 million people early in the year, with a disproportionate drop among individuals with incomes just above the 400% federal poverty level subsidy cliff.
• General Healthcare Inflation: Elevated healthcare costs are continuing to pressure the market, with projections pointing toward continued premium growth heading into future years as detailed by CNBC.

Policy and Administrative Changes

• Budget and Legislative Shifts: Changes under the American Medical Association advocacy tracking have reduced federal funding for certain health programs and altered rules for marketplace participants. Meanwhile, lawmakers have introduced proposals in Congress to reinstate enhanced subsidies, as reported by Becker's Payer.
• Fraud and Integrity Enforcement: The Trump administration enacted stricter marketplace integrity rules, moving to disenroll hundreds of thousands of enrollees flagged for improper or missing documentation while issuing targeted refund checks to other participants.

If you miss the annual Open Enrollment deadline on HealthCare.gov, you generally cannot sign up for or change a standard health insurance marketplace plan until the next open enrollment period.

Immediate Consequences

• No standard enrollment: You must wait until the next yearly Open Enrollment window opens (which starts November 1) unless you qualify for an exception.
• No federal fine: There is no federal penalty fee for being uninsured. However, a few specific states (like California, Massachusetts, New Jersey, Rhode Island, and D.C.) charge their own state tax penalties if you lack health coverage.
• Out-of-pocket risk: Going without insurance means paying full price for routine doctor visits, prescription drugs, or emergency medical care.

Alternative Options Available Year-Round

If you miss the deadline, you may still get coverage through:

• Special Enrollment Period (SEP): If you experience a qualifying life event—such as losing job-based coverage, getting married, having a baby, or moving to a new state—you get a 60-day window to enroll.
• Medicaid or CHIP: If your income qualifies you, you can apply and enroll in these government programs at any time during the year.

The minimum income to qualify for Affordable Care Act (ACA) marketplace subsidies in 2026 is $15,650 for a single person (100% of the Federal Poverty Level).

2026 Minimum Income by Household Size

To qualify for premium tax credits through HealthCare.gov, your household income must be at least 100% of the Federal Poverty Level (FPL):

• 1 person: $15,650
• 2 people: $21,150
• 3 people: $26,650
• 4 people: $32,150
• 5 people: $37,650

(Note: Higher thresholds apply in Alaska and Hawaii due to different federal poverty guidelines.)

Important Rules to Know

• Medicaid Expansion: If your income falls below 138% of the poverty level ($20,783 for an individual) and you live in a state that expanded Medicaid, you will likely qualify for Medicaid instead of a marketplace plan.
• Under 100% FPL: If you earn below 100% of the FPL and live in a non-expansion state, you may fall into the "coverage gap" and not qualify for marketplace subsidies.
• Maximum Limits: Subsidies are generally structured for incomes up to 400% of the FPL, though enhanced federal rules cap benchmark plan costs relative to your income even above that level. You can estimate your specific costs using the KFF Health Insurance Marketplace Calculator.