10/16/2026
Premium Tax Credit Repayment Cap Eliminated
Clients who underestimated their 2026 income could face a larger tax bill than expected. The IRS and Treasury Department have released proposed regulations that update the premium tax credit (PTC) rules under §36B to reflect changes made by the One Big Beautiful Bill Act (OBBBA). The biggest change: starting with 2026 returns, the repayment caps in former §36B(f)(2)(B) no longer apply, so taxpayers must pay back every dollar of excess advance PTC (APTC).
The enhanced subsidies have expired, and the 400% federal poverty line limit is back, so self-employed clients, early retirees and anyone with uneven income have the most at stake. The proposal also covers the PTC consequences of failing to meet Medicaid community engagement requirements, limits for certain lawfully present immigrants beginning in 2027 and stricter Marketplace verification in 2028.
Report income changes to the Marketplace now, and review any updates to Form 1095-A, Health Insurance Marketplace Statement, and its instructions before filing season.