Most years, an open enrollment guide is a boring piece of writing. Two dates, a reminder not to procrastinate, done. This year is not that, and I'd rather tell you why than pretend otherwise.
Two things make the 2027 season different. The window runs November 1 to January 15, which CMS confirmed in August after a court threw out the rule that would have shortened it. There's still an appeal pending, so I'm not calling it permanent. And separately, the subsidies that made the last four years affordable for a lot of my clients are gone. Neither of those is in your control. What you do about them is.
When it opens: November 1, 2026
This part isn't in dispute. If you're in Florida, or any of the other states that use HealthCare.gov, open enrollment for 2027 coverage starts November 1, 2026.
One catch if you're not in Florida. Seven of the nineteen states I'm licensed in run their own marketplaces instead of using HealthCare.gov, and they set their own calendars: Colorado, Georgia, Illinois, Kentucky, Maryland, Nevada and Virginia. Most are on the same November 1 to January 15 window as Florida. Two run longer, with Illinois going to January 31 and Virginia to January 29. A couple haven't posted final dates yet, so if you're in one of the seven, ask me rather than going by Florida's calendar. Texas uses HealthCare.gov, so it runs on the Florida dates.
December 15 doesn't move, though. In all seven, that's still the last day to start coverage January 1.
Employers are on a different clock entirely. Group coverage renews on your own renewal date rather than the January calendar, and the HRA routes depend on individual open enrollment, which is what makes right now the setup window. The small business guide walks through both. It's a one-second answer, and it's the kind of thing that costs people a month of coverage.
When it closes: January 15, with one caveat
Here's where it landed.
A federal rule finalized in 2025, the Marketplace Integrity and Affordability rule, would have cut open enrollment short, ending it December 15 in every HealthCare.gov state instead of the January 15 people had gotten used to. In June 2026 a federal judge vacated that provision along with several others. In July, the government appealed.
In early August, CMS confirmed that enrollment for 2027 coverage will run November 1 through January 15, 2027. That's the operating answer for Florida and every other HealthCare.gov state. The appeal is still pending, so I won't call it permanent. If the government wins it later, December 15 could come back. That's the only reason I'd still plan around December.
What I tell clients
Don't build your plan around a deadline that's still in litigation. Treat December 15, 2026 as your deadline and the uncertainty stops mattering to you entirely.
The date I'd circle: December 15, 2026
December 15 is the right target for a reason that has nothing to do with the lawsuit.
It's the last day to pick a plan that starts January 1, 2027. That's true under either outcome. If the shortened window is reinstated, December 15 was the deadline anyway. If January 15 holds, enrolling after December 15 means your coverage doesn't begin until February 1, and you've bought yourself an uninsured January.
I've watched people lose a month of coverage to this exact misunderstanding. They hear "January 15" and assume the coverage starts in January too. It doesn't. The deadline and the start date are two different things.
What actually changed for 2027
The dates get the attention. These changes will cost people more money.
The subsidy cliff is back
From 2021 through 2025, enhanced premium tax credits smoothed out the old subsidy cliff, so income above four times the federal poverty level didn't mean losing help all at once. Those enhancements expired December 31, 2025 and were not renewed.
The original structure is back: above 400% of the federal poverty level, you get no premium tax credit at all. Not a smaller one. None. For 2027 coverage that line sits at $63,840 for a single person and $132,000 for a family of four in the continental U.S. Those figures come off the 2026 poverty guidelines, because the marketplace always runs a year behind. If you look up this year's numbers you'll get a different answer and think I'm wrong.
What that means in practice is that a raise, a good contract year, or a spouse picking up extra work can push a household over the line and add hundreds of dollars a month to their premium. This is the single biggest thing I'm working through with self-employed clients right now, because 1099 income is exactly the kind that moves.
Out-of-pocket maximums jumped hard
For 2027, the maximum out-of-pocket limit rises to $12,000 for self-only coverage and $24,000 for family coverage, up from $10,600 and $21,200. That's about a 13% increase in one year, well ahead of the usual adjustment, because the formula behind it was rewritten.
Your out-of-pocket max is your worst-case number: the most you'd pay for covered in-network care in a year. In a healthy year you'll never touch it. In a bad one it's the number that matters more than your premium, which is why I'd rather you know it went up before you shop on monthly cost alone. (If that framing is new, premium vs. deductible is the guide to read first.)
Two smaller changes worth knowing
- Repayment caps are gone. If you take advance premium tax credits and underestimate your income, you now repay the full excess at tax time. The old caps that limited what you'd owe back are no longer there. For anyone with variable income, that raises the cost of a sloppy income estimate, and it's a big part of why I'd rather set yours carefully than optimistically.
- No more automatic Bronze-to-Silver moves. The marketplace can no longer auto-shift an enrollee who qualifies for cost-sharing reductions into a comparable Silver plan. If you auto-renew without looking, you can quietly stay in a plan that leaves that help on the table.
If you miss the window
Missing open enrollment isn't the end of the road, but the road narrows.
The usual path is a special enrollment period, which opens when something real happens: you move, get married, have a baby, or lose other coverage. These are documented and time-limited, generally 60 days from the event. When the trigger is job coverage ending, COBRA and the marketplace start two 60-day clocks at once, and they lead to very different prices.
The other path is the one most people don't know exists. Medically underwritten private plans sold outside the marketplace can be applied for any month of the year, with no qualifying event. The tradeoff is real: they're underwritten, so health history matters, and they don't carry the same ACA protections. For some people they're a genuinely good fit. For others they're a bad idea. That's a conversation, not a web page.
How I'd use the next few months
- Now through October: get a realistic 2027 income estimate on paper, especially if you're 1099. With the cliff back and the repayment caps gone, that number does more work than it used to.
- November 1: plans and prices go live. Look at your actual renewal instead of assuming it rolls over sensibly; see the auto-renewal change above.
- By December 15: be enrolled. Coverage starts January 1 and the litigation becomes somebody else's problem.
Questions I'm already getting
Will the deadline change again before November?
It might. The appeal is live and I can't promise you an outcome. That's exactly why I point people at December 15. It's the one date that works under every scenario, so you don't have to track a court docket to keep your coverage.
My premium went up a lot. Did I do something wrong?
Almost certainly not. If you were getting enhanced subsidies through 2025, part of what you're seeing is those going away, not your plan getting worse or your carrier singling you out. It's worth re-shopping anyway, because the plan that was right under the old subsidy math often isn't the right one under the new math.
Should I just auto-renew?
I'd rather you didn't, this year especially. Between the subsidy reset, the higher out-of-pocket limits, and the end of automatic Bronze-to-Silver moves, auto-renewing is more likely than usual to land you somewhere that no longer fits. Ten minutes of looking is cheap.
Does it cost me anything to have you handle this?
No. Carriers build broker commission into the plan price whether you use one or not, so you pay the same premium either way. If you enroll yourself, that money just stays with the carrier.
Want your 2027 options before the rush?
Send me your situation now and I'll have your comparison ready when plans go live November 1, including whether the subsidy cliff is going to catch you. Free, no pressure.
Get my options →The bottom line
Open enrollment runs November 1, 2026 through January 15, 2027. The appeal is still live, with arguments expected in late October, so the closing date could change for future years. For this season, January 15 is the answer. December 15 is still the date I'd put on the fridge, because it's the last day to start coverage January 1.
The bigger story isn't the calendar, though. It's that the subsidy math genuinely changed underneath everyone. If your premium jumped and you don't know why, or you're self-employed and not sure which side of the cliff you'll land on, that's worth a conversation before November, not during it. I'll tell you straight, even if the answer is that you're better off where you are.