Got a Raise While on an ACA Plan? For 2026, There's No Cap on the Subsidy You Pay Back.

If you buy health insurance on HealthCare.gov and your 2026 income is running ahead of the number you gave them last fall, you have a bill coming in April. This year, nothing caps it.

Until now, the IRS limited how much of an overpaid subsidy you had to hand back. On 2025 returns, a single filer under 400% of the poverty line paid back $1,625 at most. For 2026, that limit is gone. You repay every dollar.

The fine print got finer

The ACA’s premium tax credit is paid in advance, straight to your insurer, based on what you guessed you’d earn. At tax time, the IRS redoes the math with what you actually earned. Guess low, and the difference comes out of your refund.

The repayment cap was the cushion for people who guessed honestly and then got a raise, picked up overtime, or started a side gig. The One Big Beautiful Bill Act removed it for tax years starting after December 31, 2025. On October 14, Treasury and the IRS put it in proposed regulations. The text is blunt: “the full amount by which APTC exceeds PTC allowed” now gets added to your tax bill.

Treasury pitched the package as fraud control. “Hardworking American taxpayers should not be forced to subsidize health care for people who are ineligible under federal law,” Treasury Secretary Scott Bessent said. Fair enough for phantom enrollees. But the person this change actually catches isn’t a fraudster. It’s the cashier who got promoted in June.

What it costs you

Take a single filer who estimated $31,300 for 2026. That’s 200% of the poverty guideline used for 2026 plans, so the expected contribution toward the benchmark silver plan is 6.60% of income, about $2,066 a year. Say the benchmark costs $600 a month and that’s the plan you picked. Your advance credit runs about $5,134 for the year.

Now say you actually earn $55,000. That’s about 351% of poverty, and the contribution jumps to 9.96%, or $5,478. Your real credit is $1,722. The gap is $3,412.

Under the 2025 rules, you’d have paid back $1,625. Under the 2026 rules, you pay all $3,412. That’s $1,787 more, from a raise you were happy about.

Above 400% of poverty ($62,600 single, $128,600 for a family of four), there was never a cap. Cross that line and you repay every dollar, same as before. What’s new is that everyone below it loses the cushion too.

Move before December 31

Log in to HealthCare.gov or your state marketplace this week and update your income. HealthCare.gov’s own wording: if you don’t report the change, “you’ll have to pay the difference back” when you file. Fixing it now cuts the subsidy for the months left, so less of the gap piles up for April.

Then park the rest. Run your own numbers with the method above and move that amount into savings now, before it turns into a surprise bill. Our budget planner helps you find where it comes from.

Close to a bracket line? Pre-tax 401(k), traditional IRA, and HSA contributions lower the income the credit uses. We ran that math in our 2027 premium post.

Open enrollment for 2027 starts November 1. When you renew, put your raise in the estimate. A smaller credit now beats a four-figure bill later. Need the basics first? Start with our ACA explainer.

The detail

The rules are REG-101576-26, published in the Federal Register on October 15, 2026. Comments are due November 30, with a phone hearing December 8 if anyone asks to speak. The cap removal comes from the statute, section 71305 of the One Big Beautiful Bill Act, so the rulemaking won’t bring it back. The 2025 caps came from Table 5 of the Form 8962 instructions, and the 2026 percentages from Rev. Proc. 2025-25. Our example assumes the full-year income figures above and a plan priced at the benchmark.

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