# State ICHRA policy in 2026: incentives, amendments and proposals

Canonical reader page: https://ichrareport.com/research/ichra-state-policy-review-2026/

Publisher: ICHRA Report

Originally published: 2026-09-12

Substantively updated: 2026-09-24

Sources checked: 2026-09-24

Data period: Selected state records checked through September 24, 2026

[Home](https://ichrareport.com/) [Research](https://ichrareport.com/research/)  State ICHRA policy in 2026: incentives, amendments and proposals

State policy

Five selected states show why enacted ICHRA tax credits, active applications, amendments and failed proposals must be read separately.

At a glance

Evidence  **Analysis of external evidence**

Event / data period  **Selected state records checked through September 24, 2026**

Review cutoff  **September 24, 2026**

By [ICHRA Report](https://ichrareport.com/about/) · Published  September 12, 2026  · Updated  September 24, 2026

Research conclusion

State activity cannot be reduced to a list of places “supporting ICHRA.” An enacted credit, an amendment, a proposal that died and an application process have different consequences for employers.

## What this review covers

This is a selected-state evidence review, not a complete 50-state legal inventory. We checked primary legislative or revenue-agency records for five examples. An omitted state should not be interpreted as having no relevant activity.

| State | Reviewed record | What the evidence establishes |
| --- | --- | --- |
| Mississippi | HB 343 | Revenue agency confirms an ICHRA-related small-employer income tax credit. |
| Indiana | HEA 1210 | 2026 amendments to the existing credit, including contribution limits and pass-through treatment. |
| Connecticut | Public Act 26-76, §85; Form CT-ICHRA | Enacted two-year credit with an active reservation application tied to Access Health CT. Official summaries disagree on employee cutoff and timing. |
| Florida | HB 141 | Died in committee March 13, 2026. |
| Texas | SB 1949, 89th Legislature | Reviewed 2025 history records a Finance referral; no enacted benefit established by that record. |

Primary records for the table: [source](https://www.dor.ms.gov/forms-resources/laws-regulations/2026-legislation) [source](https://www.in.gov/dor/files/legislative-synopsis-2026.pdf) [source](https://www.cga.ct.gov/2026/act/Pa/pdf/2026PA-00076-R00SB-00477-PA.PDF) [source](https://portal.ct.gov/-/media/drs/forms/2026/corporation/ct-ichra-application_0826.pdf) [source](https://flsenate.gov/Session/Bill/2026/141/ByVersion) [source](https://capitol.texas.gov/BillLookup/History.aspx?Bill=SB1949&LegSess=89R)

## Mississippi: use the enacted bill number

The legislature’s summary records HB 343 as signed April 6, 2026 and effective January 1, 2026. It describes qualifying employers with fewer than 50 employees, state income tax liability and an ICHRA offered in place of traditional employer coverage. The Department of Revenue identifies the same bill. [source](https://www.legislature.ms.gov/media/1368/26-summary.pdf) [source](https://www.dor.ms.gov/forms-resources/laws-regulations/2026-legislation)

Those records establish the incentive’s legislative basis. This review does not establish that a particular employer’s application is approved, that an annual allocation remains available or that every expense qualifies. The next source for an actual claim should be current revenue-agency instructions and the taxpayer’s own facts.

## Indiana: the amendment is the update

Indiana DOR’s 2026 synopsis describes HEA 1210 amendments retroactive to January 1. The per-employee credit is the lesser of actual contributions or $400 in the taxable year the employer establishes the HRA, $200 in the following taxable year, and zero thereafter. Arrangements established in taxable years beginning before January 1, 2024 are excluded. The synopsis also addresses pass-through allocations and a $10 million calendar-year program limit. [source](https://www.in.gov/dor/files/legislative-synopsis-2026.pdf)

For budgeting, a capped credit is not equivalent to cash available for every employee indefinitely. Separate the recurring benefits expense from the time-limited incentive and verify the applicable eligibility year. Treat any unapproved credit as a scenario rather than guaranteed funding.

## Connecticut: the credit has an application, but the public descriptions conflict

Connecticut's September 23 announcement says its ICHRA credit is available through Access Health CT BusinessPlus. Public Act 26-76 §85 predates the announcement and applies to income and taxable years beginning on or after January 1, 2026. The credit is the lesser of qualified contributions or $1,000 per covered employee in each of the first two eligible income years. It is nonrefundable, must be reserved through DRS, and has a $5 million statewide annual cap. [source](https://portal.ct.gov/governor/news/press-releases/2026/09-2026/governor-lamont-announces-new-state-tax-credit-to-help-small-businesses-offer-health-insurance) [source](https://www.cga.ct.gov/2026/act/Pa/pdf/2026PA-00076-R00SB-00477-PA.PDF) [source](https://portal.ct.gov/-/media/drs/forms/2026/corporation/ct-ichra-application_0826.pdf)

The enacted law and current form say  **fewer than 50 employees in Connecticut**  on the application date. The governor says “50 or fewer,” while Access Health CT says “50 or fewer full-time” and describes a 2027 start. The law's “in lieu of” group-plan wording also leaves a first-time-offer question unresolved. Read our [source-by-source Connecticut report](https://ichrareport.com/news/connecticut-ichra-tax-credit-businessplus/) before treating the credit as an approved amount or settled eligibility guidance. [source](https://www.accesshealthct.com/article/access-health-ct-businessplus-offering-health-insurance-options-for-businesses/)

## Florida and Texas: preserve the status

Florida’s history records HB 141 as having died in committee. Its proposed effective date therefore cannot be used to claim a benefit began on that date. Texas’s cited bill record is a historical proposal, not an employer credit that this review has verified as available. [source](https://flsenate.gov/Session/Bill/2026/141/ByVersion) [source](https://capitol.texas.gov/BillLookup/History.aspx?Bill=SB1949&LegSess=89R)

This is why a useful policy record stores the session, bill version, last action, effective date if enacted, agency implementation status and source-review date separately. A headline without those fields is easy to misread.

## How an employer should use this review

First evaluate the ICHRA design under federal requirements. Then have the relevant state credit evaluated as an additional financial input. State incentives do not eliminate the underlying plan obligations. [source](https://www.healthcare.gov/small-businesses/learn-more/individual-coverage-hra/)

Our [earlier state reporting](https://ichrareport.com/news/state-ichra-actions-2026/) also covers an Arizona feasibility-study announcement. A study belongs in a policy-development category; it is not evidence that employee coverage has started. Future expansion of this review should add states only when comparable primary records have been checked.

## Sources and evidence

[1 Mississippi Department of Revenue — 2026 legislation: HB 343 Confirms HB 343 creates an ICHRA-related small-employer income tax credit. No application availability or credit reservation is inferred. Source reviewed 2026-09-11](https://www.dor.ms.gov/forms-resources/laws-regulations/2026-legislation)[2 Mississippi Legislature — 2026 legislative summary: HB 343 Page 153 records signature April 6, 2026 and effective date January 1, 2026; defines qualifying employers. Reviewed excerpt; detailed claim mechanics are not reproduced. Source reviewed 2026-09-11](https://www.legislature.ms.gov/media/1368/26-summary.pdf)[3 Indiana Department of Revenue — 2026 legislative synopsis: HEA 1210 Pages 23–24 summarize ICHRA credit amendments, retroactive January 1, 2026; capped contributions and calendar-year program limit. Taxpayer eligibility and claims need current DOR instructions. Source reviewed 2026-09-11](https://www.in.gov/dor/files/legislative-synopsis-2026.pdf)[4 Office of Governor Ned Lamont — Governor Lamont Announces New State Tax Credit To Help Small Businesses Offer Health Insurance Announcement says credit now available through Access Health CT BusinessPlus and 50 or fewer employees, conflicting with enacted/form fewer-than-50 Connecticut test. Announcement is not enactment or outcome evidence. Source reviewed 2026-09-24](https://portal.ct.gov/governor/news/press-releases/2026/09-2026/governor-lamont-announces-new-state-tax-credit-to-help-small-businesses-offer-health-insurance)[5 Connecticut General Assembly — Public Act 26-76, Section 85 Enacted credit text; applies to income/taxable years beginning January 1, 2026. Fewer than 50 Connecticut employees, in-lieu-of condition, exchange channel, lesser-of formula, two years and reservation cap. Reviewed pages 76-78 of 112. Source reviewed 2026-09-24](https://www.cga.ct.gov/2026/act/Pa/pdf/2026PA-00076-R00SB-00477-PA.PDF)[6 Connecticut Department of Revenue Services — Form CT-ICHRA: Individual Coverage Health Reimbursement Arrangement Tax Credit Application Form marked New 08/26. Three-page application repeats fewer-than-50 Connecticut employee and in-lieu-of conditions, asks for two years of contributions and covered employees, and explains mailed reservation application and $5 million annual first-come cap. Source reviewed 2026-09-24](https://portal.ct.gov/-/media/drs/forms/2026/corporation/ct-ichra-application_0826.pdf)[7 Access Health CT — Access Health CT BusinessPlus: Offering health insurance options for businesses Current exchange explainer says starting in 2027 and 50 or fewer full-time employees. Those statements do not reconcile with statutory 2026 applicability and fewer-than-50 Connecticut employees; operational timing and cutoff require clarification. Source reviewed 2026-09-24](https://www.accesshealthct.com/article/access-health-ct-businessplus-offering-health-insurance-options-for-businesses/)[8 Florida Senate — 2026 HB 141 bill history History records HB 141 died in Insurance & Banking on March 13, 2026. A proposed effective date is not proof of enactment. Source reviewed 2026-09-11](https://flsenate.gov/Session/Bill/2026/141/ByVersion)[9 Texas Legislature — 89th Legislature SB 1949 history 2025 bill record shows referral to Finance, not enactment. Historical proposal, not a verified available tax benefit. Source reviewed 2026-09-11](https://capitol.texas.gov/BillLookup/History.aspx?Bill=SB1949&LegSess=89R)[10 HealthCare.gov — Individual Coverage Health Reimbursement Arrangements Federal overview of ICHRA contributions, employee classes, class-size minimums, affordability, and implementation timing. Source reviewed 2026-09-11](https://www.healthcare.gov/small-businesses/learn-more/individual-coverage-hra/)

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.