
On July 18, 2025, the IRS released Revenue Procedure 2025-25 to index the contribution percentage in 2026 for determining the affordability of an employer’s health plan under the Affordable Care Act (ACA). For plan years beginning in 2026, employer-sponsored coverage will be considered affordable under the ACA’s “pay-or-play” rules if the employee’s required contribution for self-only coverage does not exceed 9.96% of their household income for the year.
This is a significant increase from the affordability contribution percentage for 2025 (9.02%) and the highest this percentage has ever been. Applicable large employers (ALEs) will need to consider this affordability percentage in developing their health plan contribution strategies for the 2026 plan year. ALEs may be able to increase employees’ health coverage contributions for 2026 while still meeting the adjusted affordability percentage.
As background, the ACA’s pay-or-play rules require ALEs to offer affordable, minimum-value health coverage to their full-time employees (and dependents) or risk paying a penalty. The affordability of health coverage is a key point in determining whether an ALE may be subject to a penalty. An ALE’s health coverage is considered affordable if the employee’s required contribution to the plan does not exceed 9.5% (as adjusted annually) of the employee’s household income for the taxable year.
For 2026 plan years, an ALE’s health coverage will be considered affordable if the employee’s required contribution for self-only coverage under the employer’s lowest-cost plan does not exceed 9.96% of the employee’s household income. Because an employer generally will not know an employee’s household income, the IRS has provided three optional safe harbors that ALEs may use to determine affordability based on information that is available to them: the Form W-2 safe harbor, the rate of pay safe harbor and the federal poverty level safe harbor.
Contact us to see how you could minimize risk:
- Employee Benefits|
- health plan|
- HR|
Recent News
Construction Industry Fatalities Decline in 2024
In 2024, total workplace fatalities in the United States fell to 5,070, the lowest number since 2020.
How an Extra Biweekly Payroll Period in 2026 Impacts Payroll
For employers that run biweekly payroll, 2026 introduces a unique scheduling challenge.
Employee Spotlight: Lane Trust
Please help us welcome Lane to the Seubert Team as a Strategic Risk Advisor!
Employers Should Prepare for 2026 RxDC Reporting
Group health plans and health insurance issuers must annually submit detailed information on prescription drug and health care spending to the CMS.
DOL Announces Proposed Independent Contractor Rule
The DOL announced a proposed rule to rescind its 2024 final independent contractor rule and replace it with an analysis of employee classification under the FLSA.
Improving the Effectiveness of Cybersecurity Training
Workforce cybersecurity training is a critical part of a company’s security risk management program.

