2026 ACA numbers: FPL, applicable percentages, and the cliff

Last reviewed July 2026 · 5 min read

2026 is the first plan year since 2020 in which the original, statutory ACA subsidy math applies: the enhanced credits of 2021–2025 expired, the applicable percentages reverted to the indexed pre-2021 schedule (Rev. Proc. 2025-25)^[1], and the 400%-of-poverty cliff is back — one dollar of MAGI over the line and the entire premium tax credit disappears^[2].

Three numbers drive everything: your household’s federal poverty level (FPL), your MAGI as a percentage of it, and the applicable percentage — the share of income you are expected to pay toward the benchmark (second-cheapest silver) plan before subsidies cover the rest. One vintage detail trips people up: 2026 coverage uses the 2025 poverty guidelines (published January 2025)^[4], because eligibility is set against the guidelines in effect when open enrollment began^[3]. The 2026 guidelines published this January apply to 2027 coverage.

2026 coverage-year FPL and the 400% cliff

2025 HHS poverty guidelines (48 contiguous states + D.C.), which govern 2026 marketplace subsidies: $15,650 for one person plus $5,500 per additional person. Alaska and Hawaii run higher (2025 single-person guideline: $19,550 and $17,990).
Household size	100% FPL	138% (Medicaid expansion line)	400% (subsidy cliff)
1	$15,650	$21,597	$62,600
2	$21,150	$29,187	$84,600
3	$26,650	$36,777	$106,600
4	$32,150	$44,367	$128,600

The window matters at both ends: MAGI below 100% FPL generally gets no premium credit (in expansion states, incomes up to 138% go to Medicaid instead), and MAGI above 400% gets nothing at all^[2].

The 2026 applicable percentage table

Required contribution toward the benchmark silver plan, as a % of MAGI (Rev. Proc. 2025-25). Between the floor and ceiling of each band the percentage is interpolated linearly.
MAGI as % of FPL	Initial %	Final %
Less than 133%	2.10%	2.10%
133% up to 150%	3.14%	4.19%
150% up to 200%	4.19%	6.60%
200% up to 250%	6.60%	8.44%
250% up to 300%	8.44%	9.96%
300% up to 400%	9.96%	9.96%

Reading it: subsidy = benchmark premium − (applicable % × MAGI), never less than zero. A two-person household at exactly 400% FPL ($84,600) is expected to contribute 9.96% of income — about $8,426 a year — and the credit covers any benchmark cost above that^[1].

The cliff, in dollars

Because premiums are age-rated up to 3:1, the cliff is most expensive precisely for the people most likely to be near it: early retirees in their late 50s and low 60s bridging to Medicare. At $84,600 of MAGI, a 60-something couple’s benchmark premium can easily exceed $20,000 a year while their capped contribution is $8,426 — a five-figure subsidy^[6]. At $84,601, the subsidy is zero and the full repayment is due at tax time. That single dollar is one of the most expensive dollars in the tax code, which is why plans near the line hold a deliberate margin under it.

How the numbers interact

MAGI for this test is AGI plus tax-exempt interest, untaxed Social Security, and excluded foreign income^[5] — so Roth conversions, capital gains, dividends, and pre-tax withdrawals all count against the cliff, while Roth withdrawals and spending down cash basis do not. The FPL denominator is indexed each year and the applicable percentages are re-set by revenue procedure, so both the cliff’s location and the subsidy’s size drift annually. For anyone retiring before 65, the ACA years and the IRMAA lookback years overlap: income planned for one test lands in the other’s window two years later.

Try it in Deorbit Plan

The simulator computes the 2026-law subsidy — interpolated applicable percentage, age-rated benchmark premium, and the hard 400% cliff — for every pre-65 year, using the household size from your filing status. The Taxes & MAGI chart draws the 400%-FPL line against your MAGI path so cliff years are visible at a glance; the Strategy panel’s cliff-margin guard keeps fill-bracket Roth conversions a chosen buffer below it; and the Strategy Lab reports each strategy’s closest cliff approach across the whole plan.

Educational content only — not financial, tax, or investment advice.

See how this plays out with your own numbers. Try it in the simulator →