The U.S. Department of the Treasury and the Internal Revenue Service (IRS) released the “Initial 2025-2026 Priority Guidance Plan” on September 30 2025 (official PDF).
Covering July 2025 through June 2026, the plan lists over 100 projects and highlights Affordable Care Act (ACA) matters, including the ACA employer mandate 2026 penalty amounts—updated earlier by Rev. Proc. 2025-26 (Aug 11 2025)—and an April 2026 target to release the §36B premium-tax-credit indexing.
Because the plan is iterative—priorities may change or expand—employers, brokers and policy watchers should monitor IRS updates during the year.
Quick Answer: The 2025-2026 PGP flags April 2026 §36B indexing and records the new ACA employer mandate 2026 dollar amounts that large employers need for compliance and budgeting.
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Background / Context
The Priority Guidance Plan (PGP) is Treasury/IRS’s annual roadmap of tax-regulatory projects they intend to issue during the guidance-year cycle (July 1 to June 30).
While not legally binding, the PGP signals to taxpayers, practitioners and regulators which topics are being prepared for forthcoming notices, revenue procedures or regulations.
For health-coverage stakeholders, the 2025-2026 PGP highlights two ACA-related elements:
- The §36B premium-tax-credit affordability table, scheduled for April 2026, which sets the income-based contribution percentages used in Marketplace advance-premium-tax-credit (APTC) calculations.
- The §4980H employer-shared-responsibility payment amounts, already adjusted by Rev. Proc. 2025-26 (issued Aug 11 2025) for calendar-year 2026, using the statutory premium-adjustment percentage.
The plan itself does not change the law or issue numbers; it simply identifies priority areas. Final amounts and methodologies appear in separate official guidance such as revenue procedures or notices.
Table — ACA 2025-2026 Key Dates (from IRS documents)
| Date (2025-2026) | ACA-related Milestone | Source cited in PGP |
|---|---|---|
| Aug 11 2025 | Publication of Rev. Proc. 2025-26 updating §4980H(a)/(b) employer-mandate dollar amounts for 2026 | Rev. Proc. 2025-26 |
| Sept 30 2025 | Release of Initial 2025-2026 Priority Guidance Plan identifying ACA projects | IRS PGP 2025-2026 |
| Apr 2026 (target) | Planned publication of §36B premium-tax-credit affordability indexing for plan-year 2026 | IRS PGP 2025-2026 |
(All dates above appear in the official IRS PGP PDF or the referenced Rev Proc.)
Federal regulations / National findings — focus on ACA employer mandate 2026
- §36B premium-tax-credit indexing: slated for April 2026 to update the affordability thresholds that determine APTC amounts in the Health Insurance Marketplaces.
- §4980H employer mandate: Rev. Proc. 2025-26 (Aug 11 2025) already raised the 2026 shared-responsibility payment levels by applying the annual premium-adjustment percentage.
- Iterative PGP: the IRS notes the plan will be updated during the year if project priorities shift or new items emerge.
- No state-specific tables: both affordability percentages and employer-mandate dollar amounts apply nationwide.
State-level variations
States operating their own ACA Marketplaces (e.g., California, Massachusetts, New York) generally adopt the federal §36B indexing and do not issue separate §4980H penalty schedules.
Therefore, the ACA employer mandate 2026 applies uniformly across states, simplifying compliance for multi-state employers.
Impact on policyholders / consumers / SMBs — preparing for ACA employer mandate 2026
Large Employers
- Must use the Rev. Proc. 2025-26 §4980H(a)/(b) amounts to project potential employer-shared-responsibility payments for 2026.
- Should test 2026 coverage affordability for each employee using the upcoming April 2026 §36B table to avoid APTC-triggered penalties.
Illustration: An ALE with 75 full-time employees offering single-coverage at an employee-share close to the 2025 threshold must check whether the April 2026 §36B indexing lowers the affordability limit, which could expose the firm to higher §4980H(b) penalties if the offer becomes unaffordable for lower-income staff. (Illustration only — no numeric figures published yet for 2026.)
Small Employers
- Not directly liable under §4980H, yet the §36B indexing affects whether employees qualify for Marketplace APTCs, influencing small-group benefit strategies.
Marketplace enrollees / consumers
- The April 2026 §36B update will reset the income-based contribution percentages that define how much of a premium households must pay before APTCs apply.
Brokers & advisors
- Need to track both items for renewal forecasting, affordability tests and client compliance briefings.
Tip: Employers running delivery fleets or offering transport perks may review our car insurance guide to align commercial-auto costs with overall benefits budgeting, and compare affordable car insurance options to manage operating expenses.
SMBs looking at broader risk management can consult our business insurance resource for complementary coverage guidance.
FAQ
What is the IRS Priority Guidance Plan?
The PGP is the official annual work-plan released by Treasury/IRS each July-to-June cycle, listing targeted guidance projects to help taxpayers anticipate upcoming rules.
How could it affect ACA penalties and credits for 2026?
It signals the April 2026 §36B affordability-indexing project that drives Marketplace APTC amounts, and cites Rev. Proc. 2025-26 setting the ACA employer mandate 2026 penalty levels for applicable large employers.
When will §36B premium-tax-credit indexing publish?
According to the PGP, the target is April 2026 for issuing the updated income-percentage table applicable to plan-year 2026.
Who needs to track §4980H employer shared-responsibility amounts?
Applicable Large Employers (ALEs) — generally those with 50 or more full-time employees — plus their payroll/benefits staff, and the brokers or consultants advising them.
Why should small employers and brokers monitor these updates?
Even when not subject to §4980H, small-employer decisions on offering coverage often hinge on workers’ eligibility for APTCs; brokers need both figures to steer 2026 plan-design discussions.
Does the PGP guarantee publication dates?
No. The PGP is guidance-only and may be revised mid-cycle; IRS/Treasury adjust priorities as needed.
Key Takeaways
- The ACA employer mandate 2026 penalty figures come from Rev. Proc. 2025-26 (Aug 11 2025) referenced in the PGP.
- The PGP 2025-2026 covers 100 + projects (July 2025-June 2026) and is iterative, without fixed completion deadlines.
- §36B indexing is targeted for April 2026, shaping Marketplace premium-tax-credit thresholds.
- Both ALEs and brokers should track these numbers for budgeting, affordability testing and compliance.
- The PGP itself does not change the law; new figures take effect only once official guidance is released.
Conclusion
The ACA employer mandate 2026 compliance picture is defined by two official IRS actions named in the 2025-2026 Priority Guidance Plan: the Rev. Proc. 2025-26 updated §4980H penalties and the forthcoming April 2026 §36B indexing.
Large employers should start using the Rev Proc 2025-26 amounts in budget forecasts, offer-of-coverage tests and affordability analyses well before the 2026 plan year begins.
For households buying Marketplace plans, the §36B update coming in April 2026 will directly affect advance-premium-tax-credit calculations for the 2026 open-enrollment period.
Because the PGP is subject to in-year revision, all stakeholders — employers, brokers, consumer advocates and compliance teams — should monitor IRS bulletins through mid-2026 to capture any shifts in ACA-related guidance.
Key Takeaways: The PGP confirms the ACA employer mandate 2026 penalty schedule and flags April 2026 §36B indexing, underscoring the need for continuous tracking of IRS updates.
Regulatory Disclaimers
- General Compliance Notice: This article summarizes public IRS regulatory material for educational purposes and is not legal or tax advice. Consult qualified professionals for employer-specific guidance.
- Source Limitation Notice: All ACA-related statements derive exclusively from the IRS 2025-2026 Priority Guidance Plan (Sept 30 2025) and Rev. Proc. 2025-26 (Aug 11 2025); no other data were added.
- Change Notice: IRS guidance priorities may shift; employers and individuals should keep watching future IRS notices or PGP updates for the most current numbers.