The Affordable Care Act (ACA) made widespread reforms to health plan coverage when it was enacted in 2010. Since then, changes have been made to various ACA requirements for employer-sponsored health coverage. These changes include annual cost-of-living increases to certain ACA dollar limits, adjustments to ACA reporting requirements and updates to preventive care coverage guidelines.
Changes to some ACA requirements will take effect in 2027 for employers sponsoring group health plans. For example, the affordability percentage under the ACA’s employer mandate rules for applicable large employers (ALEs) will increase for plan years beginning in 2027, potentially providing ALEs with more flexibility in setting their employee contribution rates.
To prepare for 2027, employers can use this checklist to review these ACA requirements and develop a compliance strategy. Employers should ensure that their health plan documents, including the Summary of Benefits and Coverage (SBC), are updated to reflect any new plan limits. Employers should also ensure that up-to-date information is communicated to employees at enrollment time. Any changes to a health plan’s benefits for the 2027 plan year should be communicated to plan participants through an updated Summary Plan Description (SPD) or a Summary of Material Modifications.
Plan Design Changes
The following plan design requirements will change for 2027:
- Limits on cost sharing for essential health benefits;
- Coverage affordability percentage under the employer mandate rules; and
- First-dollar coverage for recommended preventive care items and services.
ACA Reporting Deadlines
- Individual statements: Employers must post a website notice by March 2, 2027, stating employees may receive a statement upon request (alternatively, employers may automatically provide statements to employees by this date); and
- ACA returns: The deadline for employers to electronically file their 2026 ACA returns with the IRS is March 31, 2027.
Links & Resources
- IRS Rev. Proc. 2026-26 indexed the ACA’s affordability percentage for plan years beginning in 2027.
- IRS Rev. Proc. 2026-22 modified the penalty amounts under the ACA’s employer mandate for 2027.
- Guidance from the U.S. Department of Health and Human Services established the cost-sharing limits for 2027 plan years.
This article is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. ©2026 Zywave, Inc. All rights reserved.
