# ICHRA affordability is 9.96% for 2026 plan years

Canonical reader page: https://ichrareport.com/news/2026-affordability-threshold/

Publisher: ICHRA Report

Originally published: 2026-09-12

Substantively updated: 2026-09-13

Sources checked: Not recorded

Data period: Not recorded

[Home](https://ichrareport.com/) [News](https://ichrareport.com/news/)  ICHRA affordability is 9.96% for 2026 plan years

Federal affordability update

For plan years beginning in 2026, the IRS affordability percentage is 9.96%. This percentage is one input in a test affecting employee premium tax credits. Learn what employers should update and why an individual calculation needs more than the percentage.

At a glance

Source review  **See linked sources**

Evidence  **Linked**

Edition  **Dated reporting**

By [ICHRA Report](https://ichrareport.com/about/) · Published  September 12, 2026  · Updated  September 13, 2026

What changed

For plan years beginning in 2026, the required contribution percentage used in the ICHRA affordability framework is 9.96%, up from the prior year's percentage. Employers should update affordability modeling, employee communications, and applicable-large-employer analysis for the plan year.

## 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](https://www.irs.gov/irb/2025-32_IRB)

## 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—does not exceed 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](https://www.healthcare.gov/job-based-help/ichra/) [source](https://www.irs.gov/affordable-care-act/individuals-and-families/questions-and-answers-on-the-premium-tax-credit)

## 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.

### Action

Employers considering a 2026 ICHRA should not reuse a 2025 affordability worksheet. Update the percentage, local premiums, workforce data, and safe-harbor assumptions before finalizing contributions.

## Sources and evidence

[1 Internal Revenue Service — Revenue Procedure 2025-25 Sets the required contribution percentage at 9.96% for plan years beginning in 2026. Source reviewed 2026-08-16](https://www.irs.gov/irb/2025-32_IRB)[2 HealthCare.gov — Individual coverage HRA offer and Marketplace coverage Federal guidance for employees evaluating affordability, premium tax credits, and enrollment choices. Source reviewed 2026-08-16](https://www.healthcare.gov/job-based-help/ichra/)[3 Internal Revenue Service — Questions and answers on the Premium Tax Credit Current premium-tax-credit affordability percentages and interaction with employer-sponsored coverage. Source reviewed 2026-09-11](https://www.irs.gov/affordable-care-act/individuals-and-families/questions-and-answers-on-the-premium-tax-credit)[4 Internal Revenue Service — ICHRA affordability safe harbors Employer-mandate safe-harbor framework for applying ICHRA affordability rules. Source reviewed 2026-08-16](https://www.irs.gov/irb/2019-42_IRB)

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.