ACA Open Enrollment Starts Nov. 1 With New ID Checks, a Broker Freeze Lawsuit and 4.6 Million Fewer People in the Individual Market

Open enrollment for 2027 ACA coverage starts Nov. 1 in most states. Idaho, Connecticut and Massachusetts open earlier, and some states already let shoppers preview premium rates.

The market people are walking into is smaller, pricier and more tightly policed than it was a year ago.

Enrollment is down sharply

Individual-market enrollment fell 18% between June 2025 and June 2026, according to a KFF analysis by Matt McGough, Justin Lo and Cynthia Cox published Oct. 14. That is a drop from 25.2 million people to 20.5 million, or more than 4.6 million. Roughly nine in ten individual-market enrollees buy through the ACA marketplaces.

The decline began during the 2026 sign-up period, when plan selections fell by 1.2 million. Effectuated marketplace enrollment, which counts people whose coverage actually took effect, fell 12% by February, from 21.8 million to 19.2 million. KFF says the drop coincides with the expiration of the enhanced premium tax credits at the end of 2025 and other policy changes.

Enrollment fell in every state except New Mexico, with wide variation in size, KFF found. KFF also warns that returning subsidized enrollees get a three-month grace period for missed payments, so terminations lag.

The Congressional Budget Office had projected marketplace enrollment would fall 25% by the end of 2026, according to the Medicare Rights Center. Further losses are expected as more people fall behind on payments, per KFF's report as described by that group.

The administration frames the drop as a fraud win

The Trump administration sees the falling numbers as a victory, crediting its anti-fraud work, according to KFF Health News. That includes the August cancellation of policies covering 760,000 enrollees suspected of being improperly signed up. A small number of them have regained coverage.

CMS also announced it was removing hundreds of agents and brokers from the marketplaces and canceling 315,000 enrollments it called unauthorized. The agency accused unscrupulous brokers of enrolling people without their knowledge, often with incomplete paperwork. Sometimes even a Social Security number was missing. CMS said canceling those enrollments saves the federal government $2.2 billion in subsidies. Many of the brokers involved were new to the federal marketplace and had participated only since 2026.

Those figures are small next to the 4.6 million drop. They do not account for it. The administration's fraud numbers and the subsidy-expiration numbers are separate stories that are landing in the same enrollment data.

New friction for people who use a broker

New rules outlined in a CMS FAQ apply only to consumers who use an agent or broker on the federal marketplace, which serves 29 states. State-based exchanges have their own rules and, in most cases, have been more successful at preventing fraudulent sign-ups, according to KFF Health News.

Every consumer using an agent will need a one-time confirmation code or link authorizing that specific agent to enroll them or change their plan. It will come by text, email or automated call from the agent's enrollment platform. Returning consumers with wrong or outdated contact information must first call the marketplace or update their application online.

Consumers CMS labels "high-risk" must verify their own identity before authorizing an agent. That covers first-time applicants and people with existing coverage who change states, work with a new agent, or pay $30 a month or less in premiums.

Joshua Brooker, who runs an insurance agency in Pennsylvania, said CMS appears to have picked those groups because "someone who is moving to a new state or switching brokers, that could be a broker trying to impersonate a consumer."

Brokers sue to stop the registration freeze

The National Association of Benefits and Insurance Professionals has sued HHS in U.S. District Court in Maryland. The complaint says the agency violated the Administrative Procedure Act by imposing a moratorium on new brokers joining the exchange and by skipping the customary public comment period.

NABIP says nearly 19,000 agents and brokers will be blocked from registering, a number it attributes to CMS's own estimates. It wants an injunction against the freeze and an order compelling CMS to run the new-agent training and registration needed for brokers to take part in open enrollment.

The group does not defend the bad actors. NABIP said the existence of fraud on the marketplaces is "not in dispute" and that it has told CMS for years that the federal marketplace needs stronger safeguards. Its objection is to banning thousands of brokers "who have done nothing wrong." It argues other measures could target scammers directly.

Costs and the January immigrant change

Families USA, a consumer advocacy group, says the average unsubsidized marketplace premium in 2026 is $741 a month, with an average deductible of $3,786. It points to a KFF poll finding 62% of adults are somewhat or very worried about affording health care.

The group also criticizes the administration for sending $500 "refund" checks to about one million enrollees with incomes above four times the poverty line. It says the money came from fees paid by insurers that are meant to fund marketplace operations, advertising and enrollment help. The administration's reasons for the payments are not laid out in the material Families USA cites.

The Medicare Rights Center says premiums are again rising sharply for 2027. Both groups point to eligibility changes in H.R. 1, the law enacted in July 2025, that bar certain lawfully present immigrants from premium tax credits. The change affecting the most people takes effect Jan. 1, 2027, per Families USA. The Medicare Rights Center cites a CBO estimate that H.R. 1 overall will leave 11.8 million more people uninsured. Families USA cites CBO's estimate that the marketplace provisions alone will leave more than one million people uninsured.

For shoppers, the practical steps are plain. Check that contact information on file is current, expect a verification code if you use a broker, and compare plans instead of auto-renewing.

NABIP's injunction request is the open item. Enrollment starts Nov. 1, and the new immigrant eligibility limits take effect two months later.