2027 ACA Affordability Is 10.22%: The 15 Numbers That Change What You Charge
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For plan years starting in 2027, the ACA affordability percentage is 10.22%. That’s up from 9.96% in 2026, and it’s the first time the number has crossed 10%. Below are the 15 figures that decide what you can charge employees next year, what you owe if you’re wrong, and what you load into your system before open enrollment.
Every year around this time, somebody in finance asks you a version of the same question: “How much can we raise the employee contribution without getting in trouble?”
For 2027, the answer moved. The IRS put out Revenue Procedure 2026-26 on July 21, 2026, and the affordability percentage went to 10.22%. That’s more room than you had last year. It’s also fifteen other numbers you need loaded correctly before your enrollment window opens, and a couple of them will quietly break your plan if you miss them. Here they are, in the order you’ll need them.
A quick note before we start: this is the plain-English version to get you oriented, not legal or tax advice. Before you act on any of it, confirm the specifics with your broker, your benefits counsel, or your filing software. My job here is to make it make sense, not to be your lawyer.
What is the 2027 ACA affordability percentage, and what does it let me charge?
The 2027 affordability percentage is 10.22% of an employee’s household income for the lowest-cost, self-only, minimum-value plan you offer. Because you don’t have anybody’s household income, you use one of three safe harbors instead. These first five numbers are the ones finance will ask about.
1. 10.22% — the 2027 affordability percentage
For plan years beginning on or after January 1, 2027, employer coverage is affordable if the employee’s required contribution for the lowest-cost self-only minimum-value option doesn’t exceed 10.22% of household income (IRS Rev. Proc. 2026-26, July 21, 2026).
I’ve watched teams treat this like a target instead of a ceiling. It isn’t a suggested contribution rate. It’s the line where the penalty exposure starts. Where you actually land inside it is a budget decision your CFO makes, not a compliance decision you make.
Do this: pull your current lowest-cost self-only rate and write it on a sticky note. Every number below is measured against that one plan.
2. 9.96% → 10.22% — the size of the change
The 2027 threshold is up from 9.96% in 2026, and 10.22% is the highest it has ever been since the ACA took effect (World Insurance / Rev. Proc. 2026-26, 2026).
That 0.26-point jump sounds small on paper. On a $50,000 salary it’s about $130 a year of additional headroom per employee. Multiply that across your full-time population and finance will absolutely notice. Which means you should walk into that meeting already knowing the number instead of getting asked for it.
Do this: run the delta for your own headcount before renewal, so you’re presenting it, not scrambling for it.
3. Three — the number of safe harbors you can pick from
You’ll use one of three: Form W-2, rate of pay, or federal poverty line. You can use different safe harbors for different reasonable classes of employees, but you have to apply your choice consistently within a class.
Here’s the comparison I wish someone had handed me in year one:
| Safe harbor | What it measures | Best for | The catch |
| Federal poverty line (FPL) | A single flat dollar ceiling for everybody | Employers who want one number and certainty | Lowest ceiling of the three — costs you the most |
| Rate of pay | Hourly rate × 130 hrs/month, or monthly salary | Hourly workforces with stable schedules | Breaks down if hourly rates drop mid-year |
| Form W-2 | Box 1 wages for that employee, that year | Salaried, stable populations | You can’t confirm it until the year is over |
Do this: name your safe harbor in writing before OE, and make sure whoever codes your 1095-C forms knows which one you picked.
4. $135.92 — the FPL safe harbor monthly ceiling
If you offer at least one self-only minimum-value option at $135.92 per month or less, you automatically satisfy affordability under the FPL safe harbor for plan years beginning January 1, 2027 through June 1, 2027 (Sequoia, 2026).
The math, longhand, so you can rebuild it yourself: the 2026 federal poverty level for a single person in the lower 48 and DC is $15,960 (HHS poverty guidelines, 2026). $15,960 × 10.22% = $1,631.11 per year. Divide by 12 and round down: $135.92 per month.
This is the number I keep taped inside a spreadsheet, because it’s the only one of the three that gives you a hard yes.
Do this: compare $135.92 to your actual lowest-cost self-only monthly rate. If you’re under it, your affordability question is answered and you can stop.
5. Six months — the FPL lookback window that trips up calendar-year plans
The FPL safe harbor lets you use the poverty guidelines in effect within the six months before the first day of your plan year. HHS usually doesn’t release updated guidelines until mid-to-late January, which is after a January 1 plan year has already started. So calendar-year plans use the 2026 FPL to set 2027 contributions (World Insurance, 2026).
Nobody told me that one. I spent an embarrassing afternoon waiting on a January number that I was never supposed to use.
Do this: if your plan year starts January 1 and you’re using FPL, lock your contribution ceiling now using the 2026 figure. You’re not waiting on anything.
What happens if I get the affordability number wrong?
Two penalties, both assessed monthly, both indexed upward again for 2027. These are the numbers that make the affordability conversation a real conversation instead of a spreadsheet exercise.
6. $3,780 — the “we didn’t offer coverage” penalty
Under Section 4980H(a), an applicable large employer that doesn’t offer coverage to substantially all full-time employees and dependents — and has at least one full-time employee getting an Exchange subsidy — owes an annual penalty of $3,780 per full-time employee, minus the first 30 (IRS Rev. Proc. 2026-22, May 4, 2026).
Show your CFO the math, not the code section. At 120 full-time employees: 120 − 30 = 90 × $3,780 = $340,200. That’s the number that gets attention. “Section 4980H(a)” is the number that gets ignored.
Do this: run that calculation for your own headcount once and keep it. You will use it in a meeting.
7. $5,670 — the “we offered it but it wasn’t affordable” penalty
Under Section 4980H(b), an employer that does offer coverage but whose coverage is unaffordable or doesn’t provide minimum value owes $5,670 per year for each full-time employee who actually receives an Exchange subsidy, capped at the (a) penalty amount (IRS Rev. Proc. 2026-22, 2026).
This is the one affordability math protects you from. It only hits for the specific employees who go get subsidized coverage, which is why it feels abstract right up until a Letter 226-J shows up with names on it.
Do this: if you’re setting contributions anywhere near the 10.22% line, document the safe harbor calculation you used, per class, with dates.
8. 60% — the minimum value floor
Separate from affordability, your plan has to pay at least 60% of the total allowed cost of benefits to count as minimum value. A plan can be perfectly affordable and still fail here.
New admins conflate these two constantly. Affordable and minimum-value are two different tests, and you need both.
Do this: get the minimum value confirmation for each plan in writing from your carrier or broker and file it where you’ll find it in an audit.
Which 2027 plan design numbers do I load before open enrollment?
These came out of Revenue Procedure 2026-24 in May 2026 and they’re the ones that go into your benefits administration system, your payroll system, and your OE guide. Every one of them is a place a wrong keystroke costs somebody real money.
[IN-POST IMAGE: “The Numbers That Break Your Plan” banner, 851×315 — sits here, before the prose below]
9. $4,500 and $9,000 — the 2027 HSA contribution limits
The 2027 HSA contribution maximum is $4,500 for self-only coverage and $9,000 for family coverage, up from $4,400 and $8,750 in 2026 (IRS Rev. Proc. 2026-24, May 2026).
The number people forget: this is the total from all sources. Your employer seed contribution counts against it. If you fund $750 and an employee elects $4,500, they’re over, and the correction lands on them at tax time.
Do this: cap the election field in your system at the limit minus your employer contribution, not at the limit.
10. $1,000 — the HSA catch-up, unchanged since 2009
Employees 55 and older can contribute an extra $1,000. It’s set by statute, not indexed, and it hasn’t moved since 2009.
Spouses can’t share it. If both are 55+, each needs their own HSA in their own name to claim their own $1,000. I’ve had that conversation more times than any other HSA conversation.
Do this: put one plain-English line about the spouse rule in your OE guide and save yourself six emails in February.
11. $1,750 and $3,500 — the 2027 HDHP minimum deductible
For 2027, a qualifying HDHP must have a deductible of at least $1,750 for self-only or $3,500 for family coverage (IRS Rev. Proc. 2026-24, 2026).
This is the sleeper on the whole list. If your HDHP deductible is sitting right at the 2026 minimum and nobody raises it, the plan stops qualifying as an HDHP for 2027 — and every HSA contribution from everyone enrolled in it becomes an excess contribution. That is a plan-level failure, not an individual one.
Do this: check your renewal documents against $1,750 / $3,500 today. Not in November.
12. $8,700 and $17,400 — the 2027 HDHP out-of-pocket maximum
An HDHP’s out-of-pocket maximum can’t exceed $8,700 self-only or $17,400 family for 2027, up from $8,500 and $17,000 (IRS Rev. Proc. 2026-24, 2026).
Same failure mode as the deductible, opposite direction. Too high and the plan stops qualifying.
Do this: verify the deductible and the out-of-pocket max in the same sitting. They fail together and they get fixed together.
13. $12,000 — the embedded individual out-of-pocket trigger
For 2027 plan years, non-grandfathered plans must include an embedded individual out-of-pocket maximum inside family coverage if the aggregate family out-of-pocket limit exceeds $12,000 (up from $10,600 for 2026).
Translation for the human on your team: one person in a family plan can’t be forced to spend past the individual limit before the plan pays. If your family out-of-pocket is above that trigger and there’s no embedded individual limit, the plan design is out of compliance.
Do this: ask your carrier directly whether your family coverage has an embedded individual out-of-pocket max. Get the answer in email.
14. $2,250 — the excepted-benefit HRA limit
The excepted-benefit HRA maximum for 2027 is $2,250, up from $2,200 in 2026 (IRS Rev. Proc. 2026-24, 2026).
Small number, easy to miss, and it lives in a system field that almost nobody re-checks year over year because it barely moves.
Do this: add it to your annual limits-update checklist so it stops being a thing you remember by accident.
H2 · What am I still waiting on for 2027?
Two things aren’t settled yet, and one of them will shape your entire renewal conversation.
15. 9.9% and 11.5% — the 2027 cost trend you’re negotiating against
Segal’s 2027 Health Plan Cost Trend Survey projects a median medical trend of 9.9% for open-access PPO and POS plans in 2027, with prescription drug trend projected at 11.5% (Segal, 2026). PwC’s Behind the Numbers projects a 9% commercial medical trend for 2027, the highest in 17 years.
This is the context for every contribution increase you’re about to communicate. Your employees are going to feel a rate change, and “the market went up” is not an explanation anyone accepts. Have the actual numbers.
Do this: put the trend figure in your OE communications, in plain words, before employees see the new rate.
The one that’s not out yet: FSA limits
Healthcare and dependent care FSA limits for 2027 hadn’t been released as of this writing. The IRS typically publishes them in the fall, often in October or November — which for a lot of employers is during open enrollment.
Do not print the prior year’s number and hope. I’ve seen a benefits guide go out with a stale FSA limit, and the fix was a correction email to the whole company plus a round of election changes in a system that had already closed.
Do this: leave the FSA figure as a placeholder in your OE materials until the IRS releases it, and build one hour into your OE timeline to swap it in.
Nobody told me that the affordability percentage isn’t the hard part.
The hard part is that fifteen separate numbers get released across four different IRS revenue procedures, on four different dates, between May and November — and no one sends you a list. There is no email. There is no alert. You find out you missed one in January, when an employee’s HSA contribution rejects or a deductible doesn’t qualify.
The admins who don’t get burned aren’t smarter. They just built a list and check it every year. That’s the whole trick.
Not all of this is urgent. Here’s the order:
- Today: check your HDHP deductible against $1,750 / $3,500 and your out-of-pocket max against $8,700 / $17,400. This is the only item on the list that can invalidate an entire plan.
- This week: compare your lowest-cost self-only monthly rate to $135.92 and decide your safe harbor.
- Before renewal: run the 4980H(a) math for your own headcount so you have it in your pocket.
- Before OE opens: load every 2027 limit into your ben admin system and your payroll system, and reconcile that they match each other.
- When the FSA limits drop: swap the placeholder and re-verify.
If you’d rather not write those OE emails from scratch — the contribution-increase email, the “what’s changing” email, the deadline reminder — I’ve got five copy-paste templates you can grab free: Steal My OE Emails.
And if you want the full execution system for running open enrollment start to finish, the Open Enrollment Mastery Kit is the 34-page playbook, the 9-tab calculator, and the timeline checklist I wish someone had handed me on day one.
FAQ
Q: What is the ACA affordability percentage for 2027? A: 10.22% of household income for the lowest-cost self-only minimum-value plan, for plan years beginning on or after January 1, 2027. That’s up from 9.96% in 2026 and it’s the highest the percentage has ever been.
Q: What is the 2027 FPL safe harbor amount? A: $135.92 per month. If your lowest-cost self-only minimum-value option costs an employee $135.92 a month or less, you automatically meet affordability under the federal poverty line safe harbor for plan years beginning January 1 through June 1, 2027.
Q: What are the 2027 ACA employer mandate penalties? A: $3,780 per full-time employee (minus the first 30) under Section 4980H(a) for not offering coverage, and $5,670 per subsidized full-time employee under Section 4980H(b) for coverage that’s unaffordable or doesn’t provide minimum value.
Q: What is the minimum HDHP deductible for 2027? A: $1,750 for self-only coverage and $3,500 for family coverage. If your plan’s deductible falls below those amounts, it stops qualifying as an HDHP and nobody enrolled in it can contribute to an HSA.
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