The 2026 ACA Subsidy Cliff: What You Need to Know Before It Hits

The 2026 ACA Subsidy Cliff: What You Need to Know Before It Hits

November 21, 20253 min read

Open Enrollment is officially underway, and this year something feels different for a lot of families. Premiums are rising, $0 plans are disappearing, and many people—especially those in their 50s and 60s—are shocked when they see their 2026 rates.

There’s a reason for that:
The enhanced ACA subsidies are ending after 2025.

That means we are heading straight toward the 2026 Subsidy Cliff, and now is the time to understand what that really means for your household.

This blog post will break it down in simple terms so you can prepare and avoid unexpected costs or subsidy loss.


What Is the 2026 Subsidy Cliff?

Since 2021, families have benefited from expanded federal subsidies that made Marketplace plans much more affordable.

Those enhanced subsidies expire on December 31, 2025, which means in 2026 the ACA goes back to the old subsidy rules.

When that happens:

  • Subsidies shrink or disappear for many families

  • Premiums increase sharply, especially for adults age 50+

  • The 400% Federal Poverty Level (FPL) cap returns

  • A small increase in income could push you over a cliff

  • Income accuracy becomes more important than ever

This change affects millions of people—many of whom don’t realize it’s coming.


2026 Income Limits: Where the Cliff Begins

Here are the projected 400% FPL thresholds for 2026—these are the income levels where subsidy eligibility can drop sharply:

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Depending on your age and local plan pricing, even crossing this line by a small amount could mean losing some—or all—of your subsidy.


Why This Matters (A Real Example)

To understand how quickly things change in 2026, here’s a real comparison:

A 63-year-old couple earning $84,000/year pays around $499/month for a Bronze plan.

If their income rises to $85,000, their premium could jump to:

👉 $2,100/month

👉 $25,200 per year

If that increase happens mid-year—maybe from a raise, bonus, overtime, new consulting income, or a retirement withdrawal—they could owe up to $19,000 in subsidy repayment at tax time.

This is why planning ahead matters so much.


How HSAs Can Help Protect Your Subsidy

One of the most powerful tools for 2026 is using an HSA (Health Savings Account) with an HSA-eligible Marketplace plan.

HSA contributions lower your Modified Adjusted Gross Income (MAGI), which is the number the Marketplace uses to calculate your subsidy.

This can:

  • Help you stay under the subsidy threshold

  • Increase your subsidy

  • Reduce your taxable income

  • Build long-term medical savings

  • Provide financial flexibility if your income changes mid-year

If you want a deeper breakdown of how HSAs can help, limits for 2026, and low-fee custodians:


👉 Download our 2026 HSA Guide for ACA Marketplace Clients


What Income Counts Toward MAGI?

Your subsidy eligibility is based on your estimated 2026 income, not last year’s tax return.

Income that counts includes:

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Child support does NOT count toward taxable income.

For a full list: www.merebenefits.com/income-page


How to Prepare Now

Here are the steps you can take right away:

✔️ Review your estimated 2026 income

Small changes matter this year.

✔️ Consider an HSA-eligible Marketplace plan

This gives you flexibility to reduce MAGI.

✔️ Avoid underestimating income

This helps prevent unexpected IRS repayments.

✔️ Gather income and tax details before your appointment

Raises, hours, bonuses, expected withdrawals, etc.

✔️ Book your enrollment appointment early

My calendar fills fast—especially in November and December.


Need Help Navigating the 2026 Subsidy Cliff?

My team and I help simplify this process at no cost.
If you want to:

✔️ Understand how the cliff affects your household
✔️ Review HSA-eligible plans
✔️ Estimate your 2026 income
✔️ Download our 2026 HSA Guide
✔️ Get support with enrollment

Call 904-654-5450 or visit www.merebenefits.com to get on our calendar.

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We do not offer every plan available in your area. Any information we provide is limited to those plans we do offer in your area. Please contact Medicare.gov or ‍1-800-MEDICARE to get information on all of your options.

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