Texas brokers are heading into one of the most consequential plan years in a decade.

This year, multiple forces are converging at once, including the expiration of expanded premium tax credits, significant carrier rate increases, insurer exits from the individual market, and increased scrutiny from the Texas Department of Insurance (TDI). Individually, each shift would demand attention. Together, they signal a fundamental reset in how coverage is priced, placed, and regulated in Texas.

Here’s what Texas brokers need to know about 2026 compliance changes and how to navigate them.

1. Premium Tax Credit Expiration: The End of Artificial Affordability

Expanded premium tax credits, introduced under recent federal legislation, expired on December 31, 2025. For many Texans, these subsidies have masked the true cost of ACA coverage for several years.

When these credits sunset:

  • Monthly premiums for individual market clients could increase dramatically
  • Some consumers may lose eligibility altogether
  • Brokers should expect higher attrition, sticker shock, and urgent re-shopping conversations

For clients who have never experienced the pre-subsidy pricing environment, 2026 renewals may feel abrupt, even if the underlying costs have been rising for years.

Broker takeaway:
Now is the time to reset expectations. Clients need to understand what’s driving cost increases and why relying solely on individual ACA plans may no longer be sustainable for many households.

2. Double-Digit Rate Hikes Are Already in Motion

Layered on top of subsidy changes is a sharp rise in base premiums.

Several insurers operating in Texas have requested double-digit rate increases, with some filings reportedly exceeding 20–30%. These increases are being driven by:

  • Medical cost inflation
  • Higher utilization
  • The anticipated withdrawal of federal subsidies
  • Ongoing volatility in the individual risk pool

Even clients who retain subsidy eligibility may feel the impact if benchmark plans shift or if income thresholds change.

Broker takeaway:
Traditional “renew and adjust” strategies will fall short in 2026. Brokers will need broader solution sets and alternative plan structures to protect both affordability and continuity of coverage.

3. Carrier Withdrawals Mean Forced Re-Placement

Compounding the pressure, some national carriers have announced plans to exit individual ACA markets in parts of Texas.

For brokers, this creates immediate operational challenges:

  • Clients must be re-homed under new carriers or plan types
  • Network disruptions may occur
  • Prescription coverage and provider access could change overnight
  • Documentation and compliance requirements increase with every forced transition

Carrier exits don’t just affect pricing; they also destabilize long-term planning for both brokers and clients.

Broker takeaway:
A shrinking carrier landscape increases risk. Diversification of solutions is crucial for maintaining strong client relationships.

4. Increased TDI Audits: Compliance Is Under the Microscope

While affordability dominates client conversations, regulators are sharpening their focus behind the scenes.

The Texas Department of Insurance is rolling out new audit initiatives that place greater emphasis on:

  • Broker disclosures
  • Documentation of client communications
  • Plan comparisons and suitability
  • Record-keeping and compliance processes

As market disruption increases, so does regulatory attention.

Broker takeaway:
In 2026, how you document decisions will matter just as much as what you recommend. The time to consider processes, clear disclosures, and defensible strategies is now.

What This Means for Texas Brokers

Taken together, these changes point to one clear reality: The individual market is becoming more expensive and more regulated at the same time.

Brokers who rely on a single model, or who wait until renewal season to act, will be playing defense.

Those who are preparing now can:

  • Proactively guide clients through subsidy changes
  • Offer alternatives when ACA options become unaffordable or unavailable
  • Reduce exposure to compliance risk
  • Position themselves as long-term strategic advisors, not transactional sellers

At Members Health Plan, we believe brokers deserve access to solutions that create stability in unstable markets, especially in Texas, where volatility has become the norm.

Looking Ahead

Texas brokers who act early and align with solutions built for volatility will be best positioned to protect their clients and their businesses.

If you’re evaluating how to navigate what’s coming next, now is the right time to start the conversation.

Answering Commonly Asked Questions

Will ACA premiums increase in Texas in 2026?
Yes. Many insurers have requested double-digit rate increases, and the expiration of expanded premium tax credits is expected to further increase out-of-pocket costs for consumers.

When do the expanded premium tax credits expire?
They expired on December 31, 2025, unless extended by future federal legislation.

What happens if my client’s carrier leaves the Texas market?
Clients will need to be re-enrolled with a new carrier or plan option, which may involve network changes, new deductibles, and updated compliance documentation.

Is TDI increasing audits for brokers?
Yes. Texas regulators are expanding audit initiatives focused on compliance, disclosures, and record-keeping, making process and documentation more important than ever.