ICHRA affordability is 9.96% for 2026 plan years

The 2026 number

IRS Revenue Procedure 2025-25 sets the applicable percentage at 9.96% for plan years beginning in 2026. The annual percentage is one input in determining whether an ICHRA offer is affordable. ^source

What it means for employees

For Marketplace purposes, an ICHRA offer is generally affordable when the employee's required contribution for self-only lowest-cost Silver coverage—after the monthly ICHRA amount—is below the applicable share of household income. If the offer is affordable, the employee generally cannot claim a premium tax credit for Marketplace coverage, even if the employee declines the ICHRA. If the offer is unaffordable and the employee opts out, a premium tax credit may be available if all other requirements are met. ^{source source}

What employers should update

• Refresh census and lowest-cost Silver premium data for every employee rating area.
• Apply the correct 2026 percentage to plan years beginning in 2026.
• Re-test contribution amounts after workforce, age, location, and premium changes.
• Separate Marketplace affordability from employer-mandate safe-harbor analysis.
• Verify that notices and enrollment materials explain premium-tax-credit consequences accurately.
• Retain the source data and assumptions used for each affordability result.

What the percentage does not answer

The 9.96% figure does not determine whether employees will view the benefit as competitive, whether local plans have adequate networks, whether dependents are affordable, or whether an ICHRA will reduce total employer cost. Those require separate employee-level analysis.

Sources and evidence

Review dates are recorded for each source above. Company pages are useful for confirming how a product is described, but they do not prove service quality or customer results.