ACA Marketplace for Immigrants: What Changes in 2027

Last updated: October 21, 2026
By ITINWorks Team

Who can still get ACA premium tax credits starting in 2027?

Four groups keep premium tax credit eligibility starting January 1, 2027: U.S. citizens and nationals, lawful permanent residents (green-card holders), Cuban and Haitian entrants, and COFA migrants from the Marshall Islands, Micronesia, and Palau. People in these groups still have to meet the usual income, tax-filing, and coverage rules to receive savings.

Public Law 119-21 calls these groups "eligible aliens" and applies the limit to tax years beginning after December 31, 2026 (26 U.S.C. § 36B(e)(2)). HealthCare.gov's immigration status page lists the same three noncitizen groups. Even if you are in one of them, you also need to:

• Have household income of at least 100% of the federal poverty level. The temporary rule that removed the 400% income cap covered tax years 2021 through 2025 only, according to the IRS premium tax credit Q&A.
• File a federal tax return and reconcile your advance credits on Form 8962. Married couples generally must file jointly, with exceptions for domestic abuse and spousal abandonment.
• Not be eligible for other qualifying coverage, such as Medicaid or affordable job-based insurance.

Which immigrants lose Marketplace subsidies on January 1, 2027?

Refugees, asylees, Temporary Protected Status holders, most people granted parole, and nonimmigrant visa holders such as students and H-1B workers lose premium tax credits on January 1, 2027. Under Public Law 119-21, they can still enroll in a Marketplace plan at full price if they meet the other eligibility rules.

Losing the premium tax credit also means losing cost-sharing reductions, the extra savings that lower deductibles and copays on Silver plans, because those are tied to credit eligibility. The table below summarizes the status-by-status picture; "full price" means you pay the plan's whole monthly premium.

*In 2026, lawfully present immigrants need household income of at least 100% of the federal poverty level to receive the credit. Status categories come from HealthCare.gov's guidance for lawfully present immigrants.

Can DACA recipients still enroll in Marketplace coverage?

No. DACA recipients cannot enroll in Marketplace coverage, with or without subsidies, because the 2025 Marketplace Integrity and Affordability final rule from CMS removed them from the definition of lawfully present, effective August 25, 2025. Job-based insurance, private plans sold outside the Marketplace, and community health centers remain open to them.

The rule reversed a 2024 policy that had briefly let DACA recipients buy Marketplace plans. CMS's fact sheet on the final rule confirms the change makes DACA recipients ineligible to enroll in a qualified health plan through the Marketplace, and HealthCare.gov now states that DACA recipients aren't eligible. A DACA recipient can still apply for Marketplace coverage for an eligible family member, such as a U.S.-citizen child. For coverage paths outside the Marketplace, see our health insurance without an SSN guide; for program basics, see the DACA guide.

Can mixed-status families still get Marketplace subsidies?

Yes. A mixed-status family can apply for Marketplace savings for members who qualify, such as U.S.-citizen children, even if a parent is undocumented. HealthCare.gov says the Marketplace cannot require citizenship or immigration information from household members who are not applying, and those members won't be asked their immigration status.

Key rules for mixed-status households, from HealthCare.gov's immigrant families page and the IRS Form 8962 instructions:

• Only applicants give status details. A state cannot deny coverage to an eligible applicant because a non-applying relative didn't share immigration or citizenship information.
• Leave the SSN field blank if someone has none. HealthCare.gov asks for Social Security numbers, but says not to enter an ITIN or other number in that field.
• An ITIN filer can claim the credit for eligible family. A parent who isn't lawfully present can't take the credit for their own coverage, but can claim it for lawfully present members of their tax family on Form 8962.
• Married couples generally must file jointly to claim the credit. If your spouse has an ITIN, see filing jointly with an ITIN spouse.

When is open enrollment for 2027 Marketplace plans?

Open enrollment for 2027 Marketplace plans runs November 1, 2026, through January 15, 2027, on HealthCare.gov. Enroll by December 15, 2026, for coverage that starts January 1, 2027. States that run their own exchanges, such as Covered California, can set different deadlines, so check your state's Marketplace before you apply.

Dates are from HealthCare.gov's dates and deadlines page. Use this checklist before you enroll:

1. Check your status against the 2027 list. Only citizens, green-card holders, Cuban/Haitian entrants, and COFA migrants qualify for savings.
2. Update your application. Log in to HealthCare.gov or your state exchange and confirm each household member's status, income, and who is applying.
3. Turn off advance credits if you no longer qualify. Excess advance payments must be repaid in full at tax time, with no cap, starting with tax year 2026.
4. Compare full-price premiums. If you lose the credit, compare Bronze, Silver, and Gold plans by monthly premium and deductible at the unsubsidized price.
5. Enroll by December 15, 2026 for January 1 coverage, or by January 15, 2027, for a February 1 start.
6. Get free help. Certified navigators listed at localhelp.healthcare.gov can walk your household through the application.

What are your options if you lose Marketplace subsidies?

If you lose premium tax credits in 2027, you can still buy a Marketplace plan at full price, enroll in job-based coverage, or check whether your state offers its own coverage program. Community health centers funded by HRSA provide sliding-scale care regardless of insurance, and Emergency Medicaid covers emergencies for people who meet state income rules.

• Job-based insurance: Employer plans don't use the Marketplace immigration rules, so ask your employer about enrollment, including after a new hire or other qualifying event.
• State programs: Some states that run their own exchanges add state-funded help. Rules change often, so confirm directly with your state's Marketplace.
• Medicaid and CHIP: Starting October 1, 2026, Public Law 119-21 also limits federal Medicaid and CHIP funding to citizens, certain green-card holders, Cuban/Haitian entrants, and COFA migrants. Some states keep covering lawfully present children and pregnant people — see one example in South Carolina's implementation notice.
• Community health centers: Find a federally funded clinic at findahealthcenter.hrsa.gov. Our community health center section explains how sliding-scale fees work.

What happens if your immigration status changes during the year?

Report any citizenship or immigration status change to your Marketplace as soon as possible, because HealthCare.gov lists it as a change that can affect your savings. Becoming a U.S. citizen is a qualifying life event, which usually gives you 60 days to enroll in or change a plan outside open enrollment.

HealthCare.gov's list of changes to report includes citizenship or immigration status, and its special enrollment page lists becoming a U.S. citizen as a qualifying change. If you get a green card mid-year, update your application so the Marketplace can recheck your savings. If your status changes the other way and you keep receiving advance credits you no longer qualify for, you will owe the full excess back when you file your tax return — the IRS confirms there is no repayment cap for tax years after 2025.

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