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ARTICLE · 15 AUGUST 2025

ACA Affordability Threshold & Employer Shared Responsibility Penalties Increase For 2026

Calfee, Halter & Griswold LLP
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On July 18, 2025, the IRS issued Revenue Procedure 2025-25, which announced that the Affordable Care Act (ACA) affordability threshold is increased from 9.02% in 2025 to 9.96% in 2026.

United StatesEmployment and HR
Jason A. Rothman
Jason A. Rothman
Erin E. Shick
Erin E. Shick
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On July 18, 2025, the IRS issued Revenue Procedure 2025-25, which announced that the Affordable Care Act (ACA) affordability threshold is increased from 9.02% in 2025 to 9.96% in 2026. Additionally, on July 22, 2025, the IRS issued Revenue Procedure 2025-26, which provides indexing adjustments for penalties under the ACA employer mandate. This is important news for employers subject to the ACA employer mandate because a) it potentially increases the cost at which a self-only coverage option must be available under a group plan to avoid the possibility of a penalty on the employer, and b) it increases the employer mandate penalty amounts.

The ACA Employer Mandate and ACA Affordability Requirement

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