Individual ACA premiums are set to rise sharply in 2026, with preliminary filings showing an average increase of about 20%, the largest proposed jump since 2018. Before you reach for the panic button (or your calculator), keep in mind: these filings are still preliminary and could come down.
Historically, final rates are often trimmed from initial requests. For example, federal review efforts have reduced rate hikes by about 1.4 percentage points in past years, saving consumers hundreds of millions of dollars.
Proposed 2026 ACA Premium Increases
ACA watchers (including me) have been sharing this scary looking (but well done) graph from the KFF Team around the internet:
National average proposed rate increase for 2026 sits around 20%, with a median of 18%.
But averages don’t tell the full story…
ACA Rate Increase Averages Are Lying Liars
While the 20% average sounds scary enough, it’s the variation beneath the surface that really matters. Some insurers are requesting increases north of 50%, while others are coming in at single digits (or even decreases). If your ICHRA strategy pins all hopes on one plan or carrier, you might be locking your employees into the worst-case scenarios.
Here’s another cut of the data from the Take Command team to illustrate the point in a few select states (more available upon request if you ask nicely or want to run ICHRA design with us):
While no category of health benefits (individual, group, level-funded, etc) are really able to escape increases this year (driving by inflation costs, increased utilization, and political uncertainty), the ICHRA market has a chance to mitigate the impact. This is especially true if your ICHRA administrator maintains can effectuate plans from a wide variety of insurance carriers and has access to a robust off-exchange line-up.
Off-exchange plans tend to show lower increases—an advantage your clients or employees could miss without the right ICHRA setup.
Why Plan Variety for ICHRA Isn’t Just Nice, It’s Essential
Some ICHRA administrators limit the plans employees can choose from. They might only support plans from insurers they’re contracted with, or restrict access to only on-exchange options.
In a typical year, that might be inconvenient. In 2026? It’s borderline reckless.
Our analysis shows that rate increases range from -5% to +59%. Roughly one in four insurers are asking for increases over 25%. If your ICHRA administrator only offers or “recommends” a few plans, and they happen to be on the high end of the scale, your clients and employees will feel it in their wallets.
Let’s give an example. Say ABC Co. offers their employees $500/mo through an ICHRA. If employees only have access to a single plan or limited plan set, a 25% increase means the employer will need to boost their ICHRA allowance to $625/mo to allow their employee to maintain purchasing power, or the employee will have to eat the cost and pay out of their paycheck.
However, if the employee has a robust set of plan options (including off-exchange), the employee will likely be able to find a different plan that meets their needs at a much lower cost.
It’s why this year, even though the average increase is 20% nationally, most Take Command clients are able to only increase their allowances 5-10% and employees still maintain purchasing power.
Off-Exchange Plans are the Unsung Hero in ACA Market Volatility
Because off-exchange plans aren’t impacted by the expiration of enhanced subsidies, they’re often less exposed to premium volatility. We’re also seeing more and more insurance companies roll-out ICHRA-specific plans that are only available off-exchange. That means lower increases, or even better plan design, for your employees. In the states sampled above, off-exchange plans show a noticeable advantage. That’s the kind of savings your people will never see if your ICHRA admin doesn’t support those plans.
Why Take Command: More choices than Healthcare.gov
Take Command offers the broadest access to both on- and off-exchange plans, empowering employees with true choice and shielding them from excessive premium spikes. Our platform is built to accommodate every ACA-compliant plan in the market, so your team gets the flexibility and control they need.
Brokers and consultants that compare Take Command’s shopping experience to others are often surprised to find 40-50% more plans available than they even knew existed.
We’ve crunched the data. We’ve built the integrations. We have deep insurance company relationships. And we’ve made it easy for your team to save money, even in a volatile year like 2026.
