ACA Open Enrollment 2027: Higher Costs, Fewer Brokers, and New Rules That Could Slow You Down

Americans shopping for 2027 ACA coverage face new identity rules, fewer brokers, rising premiums, and subsidy cuts for many immigrants.

For millions of Americans, the annual ritual of choosing health insurance is stressful enough without new rules, rising premiums, and fewer helpers to guide them through the process. This year, people shopping for 2027 coverage through the Affordable Care Act marketplace will face a notably different — and in many ways more complicated — landscape than they have before.

Open enrollment begins November 1 in most states and runs through January 15. Idaho, Connecticut, and Massachusetts began earlier, and some states have allowed early “window shopping” so consumers can preview premium rates before enrollment officially opens. What shoppers find this season will require careful planning — because the combination of new identity rules, fewer available brokers, higher premiums, and reduced subsidies could make finding and affording coverage harder than it’s been in years.

Fewer People Are Covered — and More May Drop Out

Enrollment in ACA marketplace plans has already been declining. The primary driver is the expiration of enhanced subsidies at the end of 2025, which led millions to drop or lose coverage in the first months of this year. Those subsidies had made coverage significantly more affordable for low- and middle-income households, and their loss translated directly into higher monthly bills — bills many families simply could not pay.

The Trump administration has also contributed to the enrollment drop through aggressive fraud-reduction efforts. In August, it canceled policies for 760,000 enrollees suspected of being improperly signed up. A small number of those enrollees have since regained coverage, but the vast majority lost their plans. More on that situation can be found in earlier reporting: After booting 760K off ACA health plans, the Trump administration adds some people back.

Getting Enrolled Could Take Longer This Year

One of the most significant changes this season involves new identity verification rules that apply to people using agents or brokers to enroll through the federal marketplace, which covers 29 states. The new rules, outlined by the Centers for Medicare & Medicaid Services, do not apply to state-run exchanges, which have generally been more successful at catching fraudulent sign-ups on their own.

Under the new system, every consumer working with an agent must receive and use a one-time confirmation code or link — sent by text, email, or automated phone call through one of the private enrollment platforms used by their agent — to authorize that agent to act on their behalf. Consumers with outdated contact information on file must first call the federal marketplace directly or update their information online.

A separate, more intensive identity check applies to anyone CMS labels “high-risk.” That category includes first-time applicants, people switching to a different state’s coverage, consumers changing brokers, and anyone paying $30 or less per month in premiums. These individuals must verify their identity through a third-party service such as credit bureau Experian before an agent can proceed.

Joshua Brooker, who oversees an insurance agency in Pennsylvania, explained why the $30-a-month threshold was chosen: some bad-acting agents pay the minimal premium themselves to keep a policy active and still collect a commission. But he worries the broad net cast by these rules will sweep up many legitimate consumers. He estimates

“up to 1 in 5 consumers is going to have to do extra identity proofing”

and that some may give up on getting insured altogether.

People who don’t pass the Experian identity check can call a help line or create a healthcare.gov account and upload identification such as a driver’s license, passport, or immigration papers. But that workaround isn’t seamless for everyone. Stacey Pogue, a senior research fellow at the Center on Health Insurance Reforms at Georgetown University, noted:

“Some people may have trouble not because they’re not real, but because they don’t have a credit file, or have moved, or have changed names.”

She acknowledged the changes might

“be an appropriate response by CMS that targets fraudulent enrollments but might also create extra hurdles.”

There Will Be Fewer Brokers to Help You

On top of the new consumer verification requirements, many families will also find fewer agents available to help them. In September, CMS issued a moratorium on brokers newly entering ACA coverage. Agents who were not registered with the federal marketplace in 2026 will not be allowed to help with 2027 enrollments until at least February — after open enrollment closes.

The agency said this step was necessary because a disproportionate share of compliance problems in 2026 came from newly registered agents. CMS has also removed “hundreds of non-compliant agents and brokers” this year.

But the moratorium is creating real problems for small brokerages that rely on seasonal hiring. Jason Fine, who runs a Florida brokerage, said he had planned to add up to 10 agents to his core staff of about five to handle open enrollment but has been unable to find registered agents who are still available.

“Everything they are doing in the long term makes sense,”

Fine said. But in the short term,

“I don’t know if they care about the chaos it will cause.”

He also pointed out that the restriction may inadvertently benefit large call centers — some of which were implicated in the unauthorized enrollment practices regulators were trying to stop — because they can afford to maintain year-round staffs.

“They can afford to keep a staff of 25 or 40 people all year long,”

Fine said.

Agent groups have pushed back hard. The National Association of Benefits and Insurance Professionals filed a lawsuit on October 15 against the Trump administration, arguing the moratorium unfairly targets 19,000 agents who want to sell ACA plans for the upcoming year. Health Agents for America filed a separate suit on October 21 seeking a temporary restraining order on the moratorium.

Ronnell Nolan, that group’s president, put it plainly:

“Just because you’re a new agent doesn’t mean you are fraudulent. All these agencies who have trained new agents and paid thousands of dollars now have people who won’t be able to work.”

The practical takeaway for consumers: don’t wait. Georgetown’s Pogue urged people to act quickly.

“If you rely on an agent or broker, and a lot of people do, their slots might fill up faster because there will be fewer of them to help with enrollment. I would reach out early.”

Premiums Are Rising Again — and Subsidies Are Smaller

Even setting aside the enrollment and broker complications, the cost picture for 2027 ACA coverage is difficult. Millions of Americans have already dropped ACA insurance as prices climbed following the expiration of the enhanced subsidies.

Last year’s average premium increase of 26% was among the largest on record. Other drivers included rising healthcare costs, general inflation, and labor shortages. For 2027, premiums are expected to rise again by around 15% — lower than last year but still significant.

Subsidies are still available and are tied to the cost of benchmark plans — specifically the second-lowest-priced silver-tier plan in a given area. That linkage helps soften premium hikes for subsidy recipients. But subsidies phase out entirely for households earning more than four times the federal poverty level. That threshold currently equals $63,840 for a single person, $86,560 for a couple, and $109,280 for a family of three.

Louise Norris, a health policy analyst for HealthInsurance.org, offered a tempered assessment:

“For most folks, overall affordability will stay about the same. That’s not to say it’s great, but if you were able to manage the premiums this year, it should be similar to that.”

But for agents working with lower- and middle-income families, that “similar” may still be too much. Anne Petry, who co-owns Jaggi Petry Insurance & Investments in Forsyth, Illinois, and helps clients find health insurance including ACA plans, said:

“The biggest issue we will face is affordability. There definitely will come a breaking point for people.”

Consumers are also being warned not to let their current plans automatically renew. Plans change year to year, insurers sometimes exit markets, and better options may be available. Cigna, for example, has dropped all or part of its ACA coverage in some areas. Experts urge shoppers to actively compare not just premiums but also deductibles and total out-of-pocket costs.

Those out-of-pocket maximums — the ceiling on what a consumer pays before insurance covers the rest of in-network costs — are also climbing. This year, the limit was $10,600 for individuals and $21,200 for families. In 2027, those caps will grow by 13%, reaching $12,000 for individuals and $24,000 for families. Lower caps remain in place for households earning up to 2.5 times the federal poverty level.

Norris echoed the call to shop actively:

“If you just sit on the sidelines and let the policy auto-renew, you might miss out on what could be a better opportunity.”

Many Immigrants Will No Longer Qualify for Subsidies

The One Big Beautiful Bill Act, passed by Congress last year, strips ACA subsidy eligibility from many lawfully present immigrants. Those affected include people on H-1B work visas, refugees, asylees, those with temporary protected status, and individuals with pending green-card applications.

Three groups of immigrants remain eligible: green-card holders with permanent legal status, certain Cuban and Haitian immigrants, and citizens of Micronesia, the Marshall Islands, or Palau. For immigrant families who fall outside those categories, the loss of subsidy access could mean losing health coverage entirely — a direct hit to household financial security and access to medical care.