2027 ACA Premium Tax Credit: Legislative Status Tracker
Plan for current law, not for a bill that has not passed. Right now current law for 2027 means the 400% FPL cliff.
What ACA subsidy rules apply in 2027?
Current law for 2027 is the original §36B premium tax credit, complete with the 400% federal-poverty-level cliff. The enhanced credits created by ARPA and extended by the Inflation Reduction Act expired December 31, 2025. The House passed a three-year extension in January 2026 by 230-196, but the Senate has not: S.3385 failed to reach the 60-vote threshold and a bipartisan compromise remains in negotiation with no floor action scheduled. CBO estimated that without the enhanced credits, 2027 gross benchmark premiums would be about 7.7% higher than if the credits had been extended (a comparison with the extension scenario, not the change from 2026). Open enrollment runs November 1 through January 15; the CMS rule that would have shortened it to December 15 was vacated in June 2026 and is on appeal, so enroll by December 15 to be safe and to start coverage January 1.
- Enhanced premium tax credits EXPIRED December 31, 2025.
- House passed a 3-year extension in January 2026 (230-196); Senate stalled.
- CURRENT LAW for 2027: original §36B credit with the hard 400% FPL cliff.
- CBO: without the enhanced credits, 2027 gross benchmark premiums about 7.7% higher than with an extension (not a year-over-year change).
- Open enrollment Nov 1 - Jan 15; enroll by Dec 15 for January 1 coverage.
- Update trigger: Senate floor action or enactment of an extension.
Status board
| Item | Status | Detail |
|---|---|---|
| Enhanced premium tax credits (ARPA/IRA) | Expired | Expired December 31, 2025. The 8.5%-of-income cap and the removal of the 400% FPL cliff are gone unless Congress acts. |
| House three-year extension | Passed House | Passed the House in January 2026, 230-196. |
| Senate action (S.3385 and successors) | Stalled in Senate | S.3385 failed to reach the 60-vote threshold. A bipartisan compromise is in negotiation with no floor action scheduled. |
| 2027 subsidy rules if nothing passes | Current law | Original §36B applies: sliding-scale credit up to 400% of the federal poverty level, and a hard cliff — one dollar over 400% FPL means zero credit. |
| 2027 applicable percentage table (Rev. Proc. 2026-26) | Current law | Rev. Proc. 2026-26 (2026-31 I.R.B., July 27, 2026) sets the 2027 expected contribution: 2.15% of income below 133% FPL; 3.23%–4.3% from 133% to 150%; 4.3%–6.78% from 150% to 200%; 6.78%–8.66% from 200% to 250%; 8.66%–10.22% from 250% to 300%; 10.22% from 300% to 400%. Above 400% FPL there is no credit. The 2027 required contribution percentage for the employer-coverage affordability test is 10.22%. |
| Open enrollment window | In litigation | November 1 - January 15 is the operative window. The CMS Marketplace Integrity rule shortening it to December 15 was vacated in June 2026 and is on appeal, so both dates are live. Enroll by December 15 for January 1 coverage either way. |
What the cliff does to a budget
Under the enhanced rules, nobody paid more than 8.5% of household income for a benchmark plan, and there was no upper income limit on eligibility. With those rules gone, household MAGI above 400% of the federal poverty level means zero credit — not a reduced one.
The practical consequence: a year-end Roth conversion, a capital gain, a bonus, or a self-employed spouse’s good quarter can retroactively wipe out a full year of advance premium tax credit, which you then repay on Form 8962. Model your income before you trigger it.
Update trigger: any Senate floor vote on an extension, or enactment. We re-check this page monthly while Congress is in session.
Related tools & guides
Calculator
ACA Subsidy Cliff Calculator
See exactly how far you are from 400% FPL and what crossing it costs.
OpenGuide
The 2026 Subsidy Cliff Explained
FPL tables, Form 8962 repayment, and the levers that lower MAGI.
ReadCalculator
APTC Repayment Calculator
Reconcile Form 1095-A against Form 8962 and see what you repay or reclaim.
OpenGuide
MAGI Cheat Sheet
Which MAGI the premium tax credit uses, and what counts in it.
ReadGuide
Roth Conversion Planning
The most common way marketplace enrollees accidentally cross the cliff.
ReadFrequently asked questions
- Will ACA subsidies be enhanced in 2027?
- Not under current law. The enhanced premium tax credits expired December 31, 2025. The House passed a three-year extension in January 2026, but the Senate has not passed it (S.3385 failed cloture 51-48 on Dec. 11, 2025), so the original §36B credit — including the 400% federal-poverty-level cliff — is what applies for 2027 unless a bill is enacted.
- What is the 400% FPL cliff?
- Under the original §36B rules, households above 400% of the federal poverty level get no premium tax credit at all. It is a cliff, not a phase-out: one dollar of extra income can cost a family the entire subsidy for the year, which is often five figures for older enrollees.
- What percentage of income will I pay for a benchmark plan in 2027?
- Rev. Proc. 2026-26 sets the 2027 applicable percentages: 2.15% below 133% of the poverty line, rising to 10.22% from 300% to 400%. Above 400% there is no premium tax credit. Employer coverage counts as affordable in 2027 if the employee-only premium is no more than 10.22% of household income.
- What does CBO project for 2027 premiums?
- CBO estimated (December 2024) that without the enhanced credits, 2027 gross benchmark premiums would be about 7.7% higher than if the credits had been extended. That is a comparison with the extension scenario, not the change from 2026. Your own premium depends on your plan, age, and rating area — check your renewal notice rather than the national average.
- When is 2027 open enrollment?
- November 1 through January 15 is the operative window. A CMS rule that would have shortened it to December 15 was vacated in June 2026 and is under appeal, so both dates remain in play. Enroll by December 15 either way — that is the deadline for coverage starting January 1.
Sources & References
Primary references used for this content
Enhanced ACA premium tax credits: expiration and extension proposals
Tracking of the expiration and the pending congressional proposals
View on kff.org
2027 open enrollment dates
2027 Marketplace enrollment window and state-by-state enrollment dates
View on healthinsurance.org
2025 Marketplace Integrity and Affordability Final Rule — what a court vacated
City of Columbus v. Kennedy: the District of Maryland vacated eight provisions on June 12, 2026, including the Nov 1–Dec 15 enrollment window; CMS appealed to the Fourth Circuit on July 16, 2026 and the case is pending
View on khi.org
Refundable credit for coverage under a qualified health plan
The statutory credit, including the 400% FPL eligibility ceiling
View on law.cornell.edu
2027 applicable percentage table and required contribution percentage
2026-31 I.R.B. 131 (July 27, 2026): 2.15%–10.22% table; 10.22% required contribution percentage
View on irs.gov
Premium Tax Credit (PTC)
Where advance credits are reconciled and excess amounts repaid
View on irs.gov
✓6 primary sources; links re-checked on a weekly rotation by the source watcher
Disclaimer: This calculator provides estimates for educational purposes only. Not tax, legal, or financial advice. Results may vary based on your specific circumstances. Consult a qualified CPA or tax professional for personalized guidance.