ACA Compliance Updates for 2026

Since its passage in 2010, the Affordable Care Act (ACA) has continued to evolve—introducing annual adjustments to plan limits, preventive care rules, and employer reporting obligations. For employers offering group health plans, several ACA requirements will change again in 2026, making early planning essential for compliance.

One of the most significant updates is a sharp increase in the ACA affordability percentage under the employer mandate. This shift may give applicable large employers (ALEs) more flexibility when setting employee premium contributions for the 2026 plan year.

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📌 Why Employers Need to Prepare Now for ACA Changes in 2026

ACA requirements impact:

• Health plan design
• Premium affordability calculations
• Preventive care coverage
• Employee notices
• IRS reporting deadlines

To stay compliant, employers must update plan documents—including the Summary of Benefits and Coverage (SBC)—and communicate all changes clearly during open enrollment.

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🏥 ACA Plan Design Changes Effective in 2026

1. Updated Cost‑Sharing Limits for Essential Health Benefits

The ACA sets annual limits on out‑of‑pocket costs for essential health benefits. These maximums increase each year based on federally applied cost-of-living adjustments. Employers will need to update plan documents to reflect the 2026 cost‑sharing limits once released.

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2. Increased ACA Affordability Percentage

Under the employer mandate, ALEs must offer affordable coverage to full‑time employees. The affordability percentage—used to determine whether a plan meets ACA affordability standards—will increase significantly for plan years beginning in 2026.

This higher threshold may reduce the minimum employer contribution required to meet ACA affordability, offering additional flexibility in:

• Premium strategy
• Contribution tiers
• Plan design decisions

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3. Updated Preventive Care Requirements

The ACA requires non-grandfathered group health plans to provide first‑dollar coverage (no cost‑sharing) for certain preventive services. Updated federal guidelines for recommended preventive services will apply for plan years starting in 2026, meaning employers need to confirm:

• New required preventive items
• Coverage updates with carriers
• SBC revisions
• Employee communication materials

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🗂 ACA Reporting Requirements for 2026

Employers also face updated ACA reporting deadlines next year:

Individual Statements – March 2, 2026

Employers must either:

• Post a notice on their website by March 2, 2026, informing employees they can request an ACA statement, or
• Automatically provide individual statements to employees by this date.

This applies to Forms 1095‑C (ALEs) or 1095‑B (non‑ALE plan sponsors).

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Electronic Filing Deadline – March 31, 2026

Employers must electronically file their 2025 ACA Forms 1094/1095 with the IRS by:

📅 March 31, 2026

Nearly all employers are now required to file electronically.

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✅ ACA 2026 Employer Compliance Checklist

To prepare for the upcoming changes, employers should:

✔ Update Health Plan Documents

• Apply new cost‑sharing limits
• Adjust affordability parameters
• Update preventive care coverage
• Refresh SBCs and plan summaries

✔ Review Contribution Strategy

• Evaluate premium share options
• Confirm affordability across all safe harbors
• Model employee impact for 2026

✔ Coordinate With Carriers and TPAs

• Confirm preventive service updates
• Ensure compliance with plan design rules
• Review annual updates to limits and requirements

✔ Prepare for ACA Reporting Deadlines

• Update employee notice processes
• Verify electronic filing systems
• Coordinate with payroll and benefits vendors

✔ Communicate Early With Employees

• Provide clear updates during open enrollment
• Explain any affordability or coverage changes
• Update benefits portals and resources

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🧾 Final Thoughts

The ACA continues to evolve, and 2026 brings meaningful updates affecting plan design, affordability calculations, and annual reporting. Employers should begin reviewing their health plans now to ensure full compliance before the new plan year.  Download the checklist here.

Need help preparing your organization for ACA changes in 2026? Contact us today for expert guidance and personalized compliance support.