The IRS has announced the new Affordable Care Act (ACA) affordability threshold for plan years beginning in 2026, and it’s a big jump. Under Revenue Procedure 2025-25, the threshold will rise to 9.96%, up from 9.02% in 2025.

For employers, particularly in service-based industries where labor costs are high and margins can be slim, this change has important implications for compliance, budgeting, and employee retention.

ACA Affordability Basics

What Is the ACA Affordability Threshold?

Under the ACA, applicable large employers (ALEs), those with 50 or more full-time or full-time equivalent employees, must offer:

  • Minimum essential coverage
  • Affordable coverage
  • Minimum value medical benefits

The affordability threshold determines the maximum percentage of an employee’s household income they can be required to pay for self-only coverage. If the cost exceeds the threshold, the plan is not considered “affordable,” and the employer could face penalties.

4980H Penalties at a Glance

Penalty for Not Offering Minimum Essential Coverage (§4980H(a))

  • 2025 rate: $241.67/month ($2,900 annualized) per full-time employee, minus the first 30 employees.
  • Triggered if at least one full-time employee isn’t offered coverage and gets subsidized coverage on the Exchange.

Penalty for Not Offering Affordable, Minimum Value Coverage (§4980H(b))

  • 2025 rate: $362.50/month ($4,350 annualized) per full-time employee receiving subsidized coverage.
  • Applies when coverage is offered but is unaffordable or fails to meet minimum value.

Note: Penalty amounts are indexed annually and could increase for 2026.

Historical ACA Affordability Thresholds

YearPercentage
20159.56%
20169.66%
20179.69%
20189.56%
20199.86%
20209.78%
20219.83%
20229.61%
20239.12%
20248.39%
20259.02%
20269.96%

Why the 2026 Increase Matters for Service-Based Industries

1. Labor-Intensive Workforces

Industries like hospitality, retail, food service, automotive repair, and personal services often employ large numbers of full-time staff. A higher affordability threshold can give employers more pricing flexibility on health plan contributions without breaching compliance.

2. High Turnover Rates

Service-based industries tend to experience above-average turnover. Non-compliance risks increase when benefits administration isn’t streamlined, particularly when onboarding and offboarding employees quickly.

3. Multiple Pay Structures

Many service industry employers use hourly wages, tips, commissions, or seasonal pay fluctuations. The ACA’s affordability safe harbors (W-2 wages, rate of pay, and federal poverty line) become especially important when setting contribution rates.

Potential Benefits of the Increase

Greater Flexibility in Plan Design

With the threshold rising to 9.96%, employers can set slightly higher employee premium contributions for self-only coverage while still meeting ACA affordability standards.

Reduced Immediate Penalty Risk

A higher threshold could help employers already close to the limit avoid §4980H(b) penalties, especially those offering competitive plans but struggling with premium cost-sharing compliance.

Potential Risks and Considerations

Premium Increases Could Hurt Retention

While compliance might be easier, passing more costs to employees, particularly in lower-wage service roles, could harm recruitment and retention.

Complex Payroll Coordination

For hourly or tipped workers, employers must ensure contribution calculations still align with the chosen ACA safe harbor. Payroll and HR teams need tight integration to avoid miscalculations.

Best Practices for Service-Based Employers in 2026

Review Current Plan Contributions

Assess whether your 2025 rates remain compliant under the new threshold or if you have room to adjust contributions without risking affordability.

Leverage ACA Safe Harbors

Understand and apply the W-2, rate of pay, or federal poverty line safe harbor methods to simplify compliance tracking.

Monitor Workforce Changes

Track employee hours closely, especially for variable-hour workers, to avoid unintentional ACA violations.

Communicate Clearly with Employees

If contribution amounts are changing, communicate early and clearly to maintain trust and minimize turnover.

The Bottom Line

The 2026 ACA affordability threshold increase to 9.96% may give service-based industries more breathing room in benefits pricing, but it’s not a green light to pass costs unchecked onto employees.

With high turnover, complex pay structures, and the constant challenge of compliance, service industry employers should work with benefits advisors who understand ACA rules inside and out.

What Does the ACA Affordability Threshold Mean?

The ACA affordability threshold sets the maximum percentage of an employee’s household income that an Applicable Large Employer (ALE) can charge the employee for self-only coverage under the lowest-cost plan that meets ACA requirements. This is the threshold used to determine whether the employer is offering “affordable” coverage as defined by the IRS, and whether they are at risk for Penalty B under the Employer Shared Responsibility Provisions.

For the 2025 tax year (applicable to coverage offered in 2026), the affordability threshold is 9.96%.

Practical Example: Employee Earning $50,000 per Year

If an employee earns $50,000 annually, the maximum amount that employer-sponsored self-only coverage can cost them to be considered “affordable” under the ACA is calculated as follows:

  • 9.96% of $50,000 = $4,980 per year
  • $4,980 ÷ 12 months = $415 per month (rounded)

This means an employer can charge the employee up to $415 per month for self-only health insurance coverage and still comply with ACA affordability rules.

This does not include coverage for a spouse or dependents, only the employee’s individual coverage.

What About Dependents?

The affordability threshold applies only to the cost of self-only coverage for the employee.

Employers can charge more for dependent coverage without violating ACA rules. There is currently no ACA penalty for unaffordable spouse or dependent coverage.

Some employers choose to subsidize family coverage to support recruitment and retention, but they are not required to make that coverage affordable under ACA guidelines.

Why Does the Affordability Threshold Change Each Year?

The IRS adjusts the threshold annually based on the relationship between premium growth and wage growth.

  • If premiums rise faster than wages, the threshold is typically raised, allowing employers to shift more cost to employees.
  • If wages grow faster or economic factors change, the threshold may be lowered to protect employees from excessive health costs.

For example:

  • In 2023, the threshold was 9.12%
  • In 2024, it dropped significantly to 8.39%
  • For 2025 (affecting 2026 coverage), it increased sharply to 9.96%

These shifts can have a significant impact on both plan design and employer cost-sharing strategy.

Which Is Better: A Lower or Higher Threshold?

It depends on your perspective.

For employees:

  • A lower threshold means the employer must cover more of the premium, resulting in lower monthly costs for the employee.
  • A higher threshold means employees may be required to pay more, which can reduce plan affordability.

For employers:

  • A higher threshold gives more flexibility to shift premium costs to employees, helping to control expenses.
  • A lower threshold means the employer must contribute more toward coverage to remain compliant, which may increase their financial burden.

In short:

  • Lower thresholds are better for employees
  • Higher thresholds are more favorable for employers

Key Takeaway for 2026

Employers must ensure they are not charging more than 9.96% of an employee’s household income for the lowest-cost self-only plan to remain ACA-compliant. This gives employers more flexibility than in prior years, but they should still balance compliance with offering benefits that employees will actually use.

Partner with Parker Insurance to Stay ACA Compliant and Competitive

At Parker Insurance, we help service-based businesses simplify ACA compliance while keeping benefits affordable and attractive to employees. From plan design and contribution strategy to ongoing monitoring and reporting, our team ensures you avoid costly penalties and stay ahead of regulatory changes.

Let’s make your benefits work harder for your business and your people. Contact us today to review your 2026 strategy and keep your coverage compliant, competitive, and cost-effective.

Industry: Automotive | Employees: 120 | Timeframe: First renewal cycle with Parker

Automotive dealerships and service groups operate in a fast-moving environment where workforce management, compliance, and overhead costs all demand attention simultaneously. For a regional automotive group with 120 employees, employee benefits had become a source of steady financial pressure and administrative friction rather than a competitive advantage. In their first renewal cycle working with Parker Insurance, that changed. Our automotive industry benefits practice delivered a 13% reduction in premium costs while expanding operational support, demonstrating what a year-round benefits strategy can produce for automotive employers.

The Starting Point: What the Automotive Group Was Experiencing

Premiums Rising Without Explanation

The group had watched premiums increase steadily year over year with no meaningful analysis behind the increases and no proactive effort from their broker to address them. Renewal was the only touchpoint. When the renewal arrived, the increase was presented as a given rather than a number to work against.

This pattern is common across automotive businesses. National trend data shows health insurance premiums increasing 10 to 12 percent annually for employers who accept standard carrier renewal terms without active cost containment strategy in place. Our post on how mid-market companies are cutting health insurance costs outlines the levers available to employers who want to get ahead of that cycle.

HR Carrying the Compliance and Administration Load Alone

Between renewal cycles, the group’s HR team was left to manage compliance questions, enrollment issues, and employee communications without broker support. ACA reporting requirements, eligibility updates, and day-to-day administration were being handled manually and reactively, which consumed time and created risk.

For automotive employers with mixed workforces, including salaried managers, hourly service technicians, and variable-schedule support staff, the complexity of tracking eligibility and maintaining ACA compliance is substantial. Our overview of benefits design for hourly and variable workforce employers addresses how workforce composition affects both plan design and compliance obligations.

Employee Understanding and Enrollment Gaps

With a bilingual workforce spanning multiple roles and locations, employee understanding of available benefits was uneven. Enrollment rates and benefit utilization reflected that gap. When employees struggle to understand their options, they either underutilize coverage or disengage from the process entirely, which reduces the return on every dollar the employer spends on benefits.

Parker’s Approach: Building a Benefits Program Around the Business

Full Policy and Market Review

Parker began with a comprehensive review of the group’s existing policies, comparing current coverage terms against available market options and benchmarking costs against comparable automotive employers. This analysis identified meaningful areas of overspend and opened the conversation with carriers about more competitive rates and contract terms. Our employee benefits services include this kind of data-driven benchmarking as a standard part of the engagement.

Cost Containment and Alternate Funding Strategy

Beyond carrier negotiation, Parker introduced cost containment measures and alternate funding structures designed to reduce premium volatility over time. Fully insured plans transfer risk entirely to the carrier, which means the employer absorbs the full cost of the carrier’s risk pricing. Alternate funding approaches give employers more control over that equation. Our comparison of fully insured and level-funded health insurance structures explains how each model works and what kind of employer is positioned to benefit from the alternative. For a deeper look at the range of funding options, our breakdown of level-funded, self-funded, and captive structures covers the full spectrum.

Integrated Benefits Administration Through HRIS

Parker streamlined the group’s benefits administration by connecting payroll and eligibility updates through a unified platform, implementing 360-degree integration across all technology systems. Routine tasks that had been handled manually, including enrollment processing, eligibility changes, and data reconciliation, became automated. This directly reduced the HR team’s administrative workload and improved data accuracy across systems. Parker’s HRIS services are built to deliver this kind of end-to-end integration for automotive employers managing complex workforces.

Bilingual Communication and Cross-Border Plan Options

To close the employee understanding gap, Parker developed bilingual communication materials giving Spanish-speaking employees full access to benefits information in their primary language. Parker also introduced cross-border health plan options, expanding the affordable coverage choices available to employees and improving overall enrollment quality and plan engagement.

Year-Round Engagement and Proactive Support

Parker established a cadence of regular check-ins throughout the year, replacing the reactive, renewal-only model the group had previously experienced. Compliance questions, enrollment issues, and benefits questions were addressed in real time through Parker’s HR Hotline, giving the HR team on-demand support rather than waiting for issues to accumulate. The value of aligning benefits strategy with ongoing HR support is covered in more depth in our post on why benefits and HR strategy should not operate separately.

Results: What the First Renewal Cycle Delivered

13% savings at renewal against a 12% national trend increase
120 employees with maintained or improved coverage

Premium Savings That Offset the National Trend

The group achieved 13% savings at renewal while the national trend for health insurance premiums was running at approximately 12%. For an employer accepting standard renewal terms with no cost containment strategy in place, a 12% increase in total health benefit costs is the baseline expectation. Parker’s approach effectively neutralized that trend, keeping total benefit costs essentially flat while most comparable employers absorbed double-digit increases. This is the practical outcome of proactive cost containment applied before renewal, rather than accepted after it.

Reduced Administrative Burden for HR

With payroll integration and automated eligibility management in place, the HR team’s time spent on routine benefits administration dropped substantially. Enrollment processing, eligibility updates, and compliance documentation moved from manual workflows to automated ones, freeing HR capacity for higher-value work.

Stronger Employee Engagement With Benefits

Bilingual materials and clearer plan communication led to measurable improvement in employee understanding and enrollment quality. When employees can access benefits information in their primary language and engage with their options clearly, plan utilization improves and the employer’s investment in coverage generates more return.

ACA Compliance Confidence

Parker established structured processes for ACA reporting and ongoing compliance monitoring, giving the group confidence that their obligations were being tracked and met throughout the year. For automotive employers with hourly and variable workforces, ACA compliance carries particular complexity around FTE calculations and minimum essential coverage offers. Parker’s compliance services provide the infrastructure to manage those requirements consistently.

“Parker didn’t just show up at renewal. They helped us clean up our policies, make administration easier, and save money without cutting benefits.”

What This Looks Like for Other Automotive Employers

The combination of challenges this group faced, steady premium increases, reactive broker support, manual administration, and uneven employee communication, reflects what many automotive dealerships and service groups experience. These are not problems that resolve themselves at renewal. They compound over time as premiums drift higher, HR capacity shrinks, and employee engagement with benefits weakens. A parallel result was achieved for a restaurant group of comparable size, detailed in our case study on how Parker saved a local restaurant group 10 to 20 percent in benefit costs, demonstrating that this model delivers consistent outcomes across industries with similar workforce profiles.

Parker Insurance works with automotive employers throughout the year to build the kind of benefits infrastructure that produces these results systematically. From initial policy benchmarking to integrated administration, bilingual communications, and ongoing compliance support, our automotive industry benefits practice is built around the specific operational realities dealerships and service groups face.

The first renewal cycle is where the foundation gets built. What it produces in year two, three, and beyond is where the compounding advantage becomes clear.

Desk with a computer, cell phone and desk in black and white

What is it?

Telemedicine is a form of technology-based communication that allows a doctor and patient to communicate without being in the same physical space.

How does it work?

Through the use of technology, communication is facilitated either in a real-time or delayed setting. Usually a patient is able to communicate from his or her home with a doctor through a live video, audio or patient data transfer system. Doctors can see the patient and assess his or her symptoms, as well as obtain the patient’s records and medical history from electronic medical records.

Is telemedicine a substitute for in-person doctor’s visits?

No. A virtual appointment is good for a number of mild conditions, but is not suitable for severe symptoms like a high fever or a debilitating cough. Additionally, you should NOT use a virtual appointment to seek treatment for situations like a chronic condition, complex conditions, life-threatening conditions, anything requiring a test or hands-on exam, or broken bones, sprains, or other serious injuries.

Want more information? Please see your HR for more information on telemedicine offerings.

New York, USA - 5 September 2014: Monochrome view looking up at the New York State Supreme Court Building and the US Justice Building, in Lower Manhattan, New York.

Annual Compliance Deadlines for Health Plans

Employers that provide group health plan coverage to their employees are subject to numerous compliance requirements throughout the year, such as requirements for reporting, participant disclosure and certain fee payments. For example, employers with group health plans may be required to:

  • File a Form 5500 by the last day of the seventh month following the end of the plan year (or request a filing extension);
  • Provide Medicare Part D creditable coverage disclosures to plan participants by Oct. 15 of each year; and
  • Pay Patient-Centered Outcomes Research Institute (PCORI) fees by July 31 of each year.

This Compliance Overview contains a high-level summary of the various compliance requirements and associated deadlines that health plan sponsors should be aware of throughout the year. It also summarizes annual notice requirements for group health plans. Please note that certain deadlines for non-calendar year plans may vary from what is outlined below.

CALENDAR YEAR DEADLINES

This chart only addresses recurring calendar year compliance deadlines. The chart does not include other requirements that are not based on the calendar year. For example, a plan administrator must provide a COBRA Election Notice to a qualified beneficiary after a qualifying event occurs. This type of notice requirement is not addressed in the chart below. Also, state laws may impose additional obligations. Users of this chart should refer to the specific federal or state law at issue for complete information.

Annual Deadlines

  • Employers that sponsor group health plans are subject to numerous compliance requirements throughout the year.
  • Not all of these compliance requirements will apply to every employer.
  • For example, only employers with self-insured health plans are required to pay PCORI fees.

Action Steps

  • Health plan sponsors should work with their advisors to determine which recurring deadlines apply to them.
  • In addition to the compliance requirements described in this chart, it’s important for plan sponsors to monitor legislative and regulatory developments.

Annual Compliance Deadlines