Recent Court Rulings Offer Critical Protections for ACA Marketplace Enrollees

07.28.2026

More than 19 million Americans rely on the ACA marketplaces for coverage, and the majority of these individuals qualify for a premium tax credit (PTC) that lowers the cost of their monthly premiums. Enrollment is down in 2026 largely because Congress let enhanced premium tax credits expire — a decision that more than doubled 2026 premiums for enrollees who rely on this help. Policies included in H.R. 1 also cut eligibility for PTCs and added new paperwork requirements, making marketplace coverage more expensive and administratively burdensome.

But the Trump Administration also finalized two major marketplace regulations (one in 2025 and one in 2026) that will make coverage more expensive, more challenging to enroll in, and less generous in 2027 and beyond. Both regulations have been challenged in court, and recent rulings have blocked or paused implementation of many of the harmful policies. Here’s a roundup:

Marketplace Integrity and Affordability Rule

In June, a federal district court judge issued an opinion finding that the following policies in the 2025 Marketplace Integrity and Affordability regulation were unlawful (*) or arbitrary and capricious (**).

The following policies — which had already been put on hold since last August — will not be implemented.

See our blog from last June for more information about these policies and the harm they could have caused had they been implemented. The administration has appealed the decision.

Policies that would have sunset at the end of 2026	Policies that would have been permanent
Imposing $5 minimum premiums for people who are automatically re-enrolled*	Allowing insurers to deny enrollment to people with past-due premiums*
Requiring marketplaces to end/deny advance payments of the PTC to people who have not reconciled past APTCs with the IRS*	Requirement that all marketplaces end their annual open enrollment period by December 30 starting with the open enrollment period for 2027 coverage**
Requiring people to submit documentation to verify eligibility for a Special Enrollment Period before being permitted to enroll**	Elimination of an automatic 60-day grace period for people to submit verification to resolve income inconsistencies*
Requiring people with income below 100% of the poverty level and people without data in the federal data hub to submit additional documentation to verify income**	Setting wider ranges of acceptable actuarial value variation (which would have allowed insurers to sell less generous silver plans, reducing the size of the PTC)**

Annual Marketplace Rule for 2027

In July, in response to plaintiffs’ request for emergency relief, a federal district court judge issued an opinion ordering stays on the following provisions from the 2027 marketplace regulation (many of which are nearly identical to the provisions challenged in 2025 marketplace integrity and affordability rule), stating that they are likely to be unlawful (*) or arbitrary and capricious (**).

These provisions will not be implemented while the case is making its way through the court.

For the time being, marketplace enrollees will not face the additional barriers to coverage, increased costs, and less generous coverage that would have accompanied implementation of these policies. See our blog from May for more details on these policies and the harm they could cause if implemented.

Barriers to coverage

Requiring marketplaces to end/deny advance payments of the PTC to people who have not reconciled past PTCs with the IRS*
Requiring people with income below 100% of the poverty level and people without data in the federal data hub to submit additional documentation to verify income**
Requiring people to submit documentation to verify eligibility for a Special Enrollment Period before being permitted to enroll in 2027 and beyond**

Increased costs

Allowing the maximum out-of-pocket limit for bronze plans to be increased above the statutory limit*
Expanding eligibility for catastrophic plans*

Less generous coverage

Weakening network adequacy and essential community provider standards**
Eliminating the requirement for marketplaces to offer standardized plans and the limit on the number of non-standardized plans**

What now?

The Trump Administration keeps pushing policies that would raise costs and make coverage harder to get — but the courts keep finding these policies are illegal. These recent decisions offer important protections for people who rely on the ACA marketplaces for coverage.

In the continued absence of PTC enhancements and in the face of declining marketplace enrollment, premiums will continue to rise in most states in 2027 (see our Premium Rate Tracker for the latest on proposed 2027 rates in your state). But this is a key moment to ensure that people with marketplace coverage, enrollment assisters, and community-based providers know the current lay of the land heading into open enrollment for 2027 coverage.