ACAACAIndexSubsidy rules, calculated
2026 eligibility

Below 100% FPL and the premium tax credit in 2026

Apply the narrow estimated-income rule and the 2026 removal of the immigration-status exception below the poverty line.

Ruling
The usual PTC minimum is 100% FPL. A narrow rule can protect some taxpayers whose Marketplace estimate was at least 100% FPL and received APTC, but the former below-poverty exception based on immigration-related Medicaid ineligibility no longer applies for 2026.

Separate two historical exceptions

The estimated-income rule may apply when the Marketplace reasonably projected at least 100% FPL, APTC was paid, and the taxpayer did not intentionally or recklessly provide incorrect facts. The prior lawfully-present immigrant exception was changed by enacted law for 2026.

Medicaid-gap results remain state-specific

Adults below the federal PTC floor may also be ineligible for Medicaid in a nonexpansion state. That coverage gap does not itself create federal PTC eligibility. Use the state's current Medicaid decision and Marketplace notice.

Decision example and mistake

A household honestly projects income above the floor but finishes slightly below after work hours are cut. The estimated-income rule needs its exact conditions. The mistake is intentionally inflating an application estimate or assuming every person below poverty qualifies.

Separate the two below-poverty pathways

Document the Marketplace's original income estimate, the facts supporting that estimate, final household income, and immigration or Medicaid eligibility. The reasonable-estimate rule and the former lawfully-present immigrant exception are different provisions. Current 2026 law removed the immigration-related exception, so a prior-year result cannot be carried forward without a fresh analysis.

Record whether the Marketplace relied on a reasonable projected income at enrollment, because final income below poverty does not by itself describe the governing exception.

Filing and enrollment checks

  • Confirm which exception, if any, supported enrollment at the time.
  • Keep records showing whether the income estimate was made in good faith.
  • Do not assume a 2025 below-poverty result remains available for 2026.

Continue with

The Medicaid coverage gap and federal PTC rulesWhich federal poverty guideline the Marketplace usesWhen and how to report Marketplace income changes

Authorities used for this guide