2026 ACA Premium-Tax-Credit Repayment and Eligibility Risk

Households receiving ACA subsidies for 2026 may face substantial repayment when actual income exceeds Marketplace estimates, especially above 400% of the federal poverty line where repayment is generally uncapped. Treasury has also proposed limiting 2027 premium-tax-credit eligibility to citizens, nationals, and certain lawfully present immigrants; the proposal is not final, so households should monitor official rules, update income estimates, and retain Form 1095-A records.