Compliance November 15, 2025

2026 ACA affordability threshold rises to 9.96% — rerun your Safe Harbor math

Third consecutive year of upward movement after the 2024 plunge to 8.39%. Most platforms update automatically — but a few cases this year needed manual override.

AJ Jaghori · Wire entry · BeyondPayroll

The IRS announced in November 2025 that the 2026 ACA employer mandate affordability threshold rises to 9.96% of household income (up from 9.02% in 2025). For Applicable Large Employers (50+ FTE), this small drift recalibrates the Safe Harbor math used to determine whether health coverage offered to full-time employees is considered "affordable" under §4980H of the Internal Revenue Code.

Practical impact: employers using the federal poverty line or rate-of-pay Safe Harbors should rerun their contribution strategies for 2026. The change is modest year-over-year, but it’s the third consecutive year of upward movement after the 2024 plunge to 8.39%.

Buyer-side takeaway

If you’re a 50+ FTE employer using ADP, Paychex, Paycor, Paycom, or WFN for ACA filing, confirm with your provider that the 9.96% threshold is reflected in your 2026 plan-year affordability tests. Most platforms update automatically — but I’ve seen at least three cases this year where a manual override was needed.

Sources

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