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Marketplace Enrollees Could Face Surprise Tax Increases Next Year Thanks to the Republican Megabill

Due to a provision in last year’s Republican megabill, some people who buy marketplace health coverage for 2026 could face much larger tax bills next year. Those higher taxes will come on top of the higher premiums that nearly all marketplace enrollees are already paying because of congressional Republicans’ failure to extend premium tax credit enhancements, which expired in December.

Most marketplace enrollees get a tax credit in advance that reduces the amount they pay for their premiums. The amount of this advance premium tax credit (APTC) is based on households’ estimated income for that year (as well as household size), with lower-income households receiving more assistance. When enrollees file their taxes, they must reconcile the amount of the credit they received with the amount for which they qualified, based on their actual income.

If their earlier income estimate turns out to be too low, people must repay the excess credit received — but since the APTC first became available in 2014, federal law has capped people’s repayment amounts. (See Table 1.)

Table 1
Income-Based Repayment Caps on Advance Premium Tax Credits, Tax Year 2025
Household IncomeRepayment Cap for Single TaxpayersRepayment Cap for Tax Households of Two or More
Under 200 percent FPL 
HH of 1: < $30,120 
HH of 4: < $62,400
$375$750
200-299 percent FPL 
HH of 1: $30,120-$45,179 
HH of 4: $62,400-$93,599
$975$1,950
300-399 percent FPL 
HH of 1: $45,180- $60,239 
HH of 4: $93,600-$124,799
$1,625$3,250
400 percent FPL and above 
HH of 1: > $60,240 
HH of 4: > $124,800
Must repay all excess APTC receivedMust repay all excess APTC received

Note: FPL = federal poverty level (based on the 2024 federal poverty guidelines, which are used to determine eligibility for premium tax credits in 2025); HH = household.

Source: IRS Rev. Proc. 2024-40

The caps were designed to protect people from large, unexpected tax bills if they experienced life changes during the year that are often impossible to predict, like receiving a lump-sum Social Security payment or inheritance or getting a new job.

People were still protected when they filed their 2025 taxes. But that’s ending this year, because the Republican megabill eliminates the APTC repayment caps beginning in tax year 2026. When marketplace enrollees file their 2026 taxes next spring, those with mid-year changes to their household size or financial situation could owe back thousands of dollars more than they would if the caps were still in place.  

Older adults could suffer the most because they are eligible for larger APTC amounts and so could face larger repayments if their income ends up higher than anticipated. Eliminating the repayment caps also harms people with fluctuating income, like freelancers, gig workers, and small business owners, who make up a large share of marketplace enrollees.

In some cases, marketplace enrollees can take steps to protect themselves from tax increases. People who experience a change in their projected annual income, household size, or offer of affordable employer-sponsored insurance should promptly update their information on HealthCare.gov or with their state-based marketplace, which will adjust the amount of their credit. But some people will face large repayment burdens even if they make reasonable predictions about their income and promptly report any changes. 

People can also protect themselves by taking less of the credit in advance than they are eligible for, based on their estimated income. But this means they will have to pay more out of pocket for their premiums. This option will likely be prohibitively expensive for many, especially because the expiration of the PTC enhancements caused 2026 premiums to spike, already leading more than a million people to drop their coverage.

Marketplace enrollees with low or moderate incomes thus face a double whammy in 2026. Their premiums have already risen considerably, and they could owe back a larger share of their income at tax time than in previous years. 

Enrollees whose estimated household income is below 400 percent of the federal poverty level ($62,600 for an individual or $128,600 for a family of four) but whose actual income turns out to exceed that “cliff” could face an even bigger jump in costs. With the PTC enhancements in place, they only needed to repay any excess APTC they received. Now that the enhancements have expired, this group is no longer eligible for APTC, so if their income rises unexpectedly above 400 percent of the poverty level, they will have to repay the entire APTC amount they received, which can be thousands of dollars. Among people who selected a plan during 2026 open enrollment and received APTCs, the average amount was $7,800 annually.

Some people exposed to large, unexpected tax increases will decide that marketplace coverage isn’t worth the potential surprise at tax time. People with lower health risks would be most likely to drop or forgo coverage, resulting in a risk pool that is sicker and thus costs more to cover. As a result, eliminating the APTC repayment caps is expected not only to reduce marketplace enrollment over time but also to raise premium costs for those who remain enrolled.

Table 2 lays out several scenarios. In some cases, people may need to repay thousands of dollars more at tax time because of this megabill provision.

TABLE 2
Impact of Eliminating the APTC Repayment Caps: Three Scenarios
HouseholdScenarioWith Repayment Caps*...Without Repayment Caps*...
Matt and Corrie, a married couple in their mid-50s, live in Idaho with two teenage children. Corrie is self-employed; Matt is looking for work. Their estimated household income is $62,000 (193 percent FPL).In July 2026 Matt gets a new job that offers affordable coverage for employees and their families. Because the family has an offer of affordable coverage, they are no longer eligible for APTCs for the remainder of the year. The family promptly reports the change to the marketplace and enrolls in Matt’s employer plan. At the end of the year, their household income is $90,000 (280% FPL).The family owes an additional $1,950.The family owes an additional $2,646.
Vera, a 63-year-old substitute teacher in South Carolina, has a projected annual income of $20,000 (128 percent FPL).In November 2026 she is deemed eligible for Social Security disability benefits after an appeal and gets a lump-sum back payment of $25,000. She promptly updates her projected income to $45,000 (288 percent FPL) and learns she is eligible for an APTC of $12,342 for the past 11 months, not the $15,917 she has already received.Vera owes an additional $975.Vera owes an additional $2,453.
Trey and Denise, a married couple in their 40s, live in West Virginia. Their projected annual income is $30,000 (142 percent FPL): Trey earns $20,000 and Denise earns $10,000.The couple separates in September 2026 and will file taxes separately. They report this change promptly to the marketplace. People who are married but file taxes separately are ineligible for APTCs, so Trey and Denise are now retroactively ineligible for APTCs for the entire year.Each person owes an additional $375.Each person owes an additional $10,067.
* The APTC repayment caps are adjusted annually. Because the caps were eliminated for 2026, we use the 2025 repayment caps here. Had the repayment caps remained in 2026, they would likely be slightly higher and provided more protection than the caps used here.