Updated poverty guidelines set the 2026 FPL at $15,960 (up from $15,650 in 2025) for a person living in the mainland US, $18,360 in Hawaii and $19,950 in Alaska. This means that the Mainland FPL Affordability Threshold for non-calendar year plans beginning in 2026 is $132.46 per month (see chart below).

Chart showing FPL affordability between calendar and non-calendar plan years

Who this applies to:

An Applicable Large Employer (ALE) that sponsors a fully insured, self-insured, or level-funded medical plan or Individual Coverage Health Reimbursement Arrangement (ICHRA). An employer is an ALE for calendar year 2026 based on averaging 50 or more full-time and equivalent employees in calendar year 2025 (subject to specific counting rules, including a combined count with commonly owned/controlled employers in a controlled group or affiliated service group).

Click here to review Benefit Compliance Solution's January 14, 2026 Alert - Federal Poverty Level Updated

Compliance update brought to you by Benefit Compliance Solutions (BCS) in partnership with Nava Benefits. The information contained in this update, including any attachments, is presented solely in the capacity of Nava as compliance consultants. Nothing contained herein should be construed as tax or legal advice or opinion or used as a substitute for consultation with professional legal counsel. Nava is not authorized to practice law, is not an attorney or law firm, and is not rendering legal advice. Communications with Nava are not subject to attorney-client privilege.