ACA Exchange Enrollment in 2026

Key Points

• Due to temporary legislative changes and regulatory approaches that reduced program integrity safeguards, from 2021 to 2024, the ACA Exchanges saw unprecedented enrollment growth, nearly half of which was suspected to be improper, phantom, or fraudulent.
• Enrollment that is improper or fraudulent is enrollment by individuals misstating their income to gain access to free plans. Phantom enrollees are unknowingly enrolled in free plans by brokers or auto enrolled. By our estimate, improper, phantom and fraudulent enrollment peaked at 5.6 million people in 2025.
• In 2025, the Trump Administration issued the Marketplace Integrity and Affordability Rule, which took significant measures to ensure those receiving subsidies were actually eligible for those subsidies.
• Currently, an estimated 19.2 million Americans are enrolled in ACA Exchange plans. This figure is higher than every year prior to 2024.
• The Trump Administration has utilized numerous tools mobilizing a full-scale effort to ensure federal subsidies are going only to those for whom they are intended. Trump Administration program integrity efforts stopped about 1.5 million enrollees from receiving subsidies they did not qualify for and ended or blocked another 1.4 million through February 2026, for a total of 2.9 million people who had previously been improperly receiving subsidies they did not qualify for.
• Unfortunately, improper, phantom, or fraudulent enrollment persists. Recent experience during and after the 2026 Open Enrollment Period strongly suggests ongoing and persistent fraud, waste, and abuse in the system. We estimate 2.6 million improper and phantom enrollments remain, including over 1 million enrollments without a social security number.
• The Trump Administration remains committed to aggressively rooting out waste, fraud, abuse, and corruption to protect Americans from unscrupulous brokers using their information to secure payments from the federal government and safeguard the program’s long-term stability for those that depend on it.

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