Explainer

Explainerreviewed Aug 10, 2026

Who loses ACA Marketplace subsidies on January 1, 2027 — and who keeps them?

Federal law changes who can receive Marketplace subsidies starting January 1, 2027. The right to buy coverage is not ending — the subsidy rules are changing. Here is exactly who is affected, and what is not changing.

The short answer

Starting with plan year 2027, federal Marketplace subsidies — the premium tax credit and cost-sharing reductions — are limited to U.S. citizens and three categories of non-citizens: lawful permanent residents (green card holders), certain Cuban and Haitian entrants, and people living in the U.S. under a Compact of Free Association. People with other lawful statuses — including refugees, people granted asylum, TPS holders, and people on work visas — remain able to buy a Marketplace plan, but without federal subsidy help.

What is NOT happening

Three things this law does not do:

  • It does not end anyone's right to buy Marketplace coverage. Lawfully present people can still enroll — the change is about the subsidy, not the plan.
  • It does not affect U.S. citizens or green card holders. Their subsidy eligibility continues under the same income rules as before.
  • It is not connected to the public charge rule. Subsidy rules and immigration consequences are separate questions — we cover public charge on its own page.

Two changes, two years — keep them apart

  • Already happened (2026). Enhanced pandemic-era subsidies expired at the end of 2025, and monthly costs rose for most enrollees. Separately, since January 1, 2026, lawfully present people with income under 100% of the federal poverty level who cannot get Medicaid because of their status no longer receive subsidies.
  • Adds on January 1, 2027. The status-based restriction described on this page takes effect. For people in the affected group, this is a second, separate change on top of what 2026 already brought.

Who keeps subsidies · who loses them

Status After January 1, 2027
U.S. citizen Keeps subsidy eligibility — nothing changes
Green card holder (LPR) Keeps subsidy eligibility
Cuban / Haitian entrant Keeps subsidy eligibility
COFA resident (Marshall Islands, Micronesia, Palau) Keeps subsidy eligibility
Refugee, asylee (no green card yet) Loses subsidy; can buy at full price
TPS holder Loses subsidy; can buy at full price
Humanitarian parole (incl. U4U) Loses subsidy; can buy at full price
Work visa (H-1B and similar) Loses subsidy; can buy at full price
Survivors of trafficking / domestic violence (T, U and similar) Loses subsidy; can buy at full price

Income rules also apply, and individual situations differ — status is one part of the picture, not the whole picture.

✓ Public Law 119-21, §71301 (statute text) · 2025 — reviewed 2026-08-10

The dates that matter

  • November 1, 2026 – January 15, 2027 — open enrollment for 2027 plans on HealthCare.gov; several state marketplaces run longer, and a pending federal appeal could still shorten the end of the window. Enrolling by December 15, 2026 is what starts coverage on January 1, 2027 — when the new subsidy rules are already in force.
  • January 1, 2027 — the subsidy change takes effect. Losing the subsidy is not the same as losing coverage, so it does not open a special enrollment period for someone who is not enrolled. For someone already enrolled in a Marketplace plan, becoming newly ineligible for the subsidy is a qualifying event: the Marketplace must allow a change to a plan at any metal level, within 60 days.

✓ Public Law 119-21, §71301 (statute text) · 2025 — reviewed 2026-08-10

What people in the affected group typically look at

  • What the full, unsubsidized price of their current or comparable plan looks like — prices vary by state, age, and plan, and typically run as ranges, not one number.
  • Whether other coverage paths exist in their situation: a job-based plan, a spouse's plan, or state programs where available.
  • What remains available if no plan is affordable — community health centers, hospital financial assistance, and other support exist regardless of coverage status. (Note: under a July 2025 federal notice, community health centers in some states may apply immigration-status restrictions; the notice is being challenged in court and applies differently by state — check with the center directly.)

You can see how these options map to your own situation, without entering your name or immigration details: [Open the Health Coverage Map →]


This page explains federal rules in plain language. It is education, not a recommendation, and not legal or immigration advice.

Sources

  1. Public Law 119-21, §71301 (statute text) · 2025
  2. CMS, HHS Notice of Benefit and Payment Parameters for 2027 · 2026
  3. CBO, Marketplace coverage estimates · 2025
  4. KFF, coverage impacts of the 2025 tax and budget law · 2025
  5. healthinsurance.org, ACA open enrollment deadlines (litigation tracker) · 2026
  6. 45 CFR 155.420, special enrollment periods (eCFR) · 2026
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Education, not a recommendation. Not legal or immigration advice.

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