ACA Marketplace enrollment crossed 24 million for plan year 2025, the highest total since the Marketplace launched in 2014. Plan year 2026 preliminary CMS enrollment snapshots showed continued growth. For brokers, the headline number matters less than what is behind it: who enrolled, why, and what it means for the renewal book.
Key Takeaways
- Plan year 2025 ACA Marketplace enrollment exceeded 24 million, the highest since the ACA launched. Enhanced subsidies under the Inflation Reduction Act extension were the primary driver.
- Medicaid unwinding starting in April 2023 pushed millions of former Medicaid enrollees into the Marketplace. That cohort has been renewing in 2024 and 2025, adding to base enrollment.
- State-based exchanges in California, New York, and Massachusetts reported disproportionate growth in broker-assisted enrollments, driven by extended OEP windows and state outreach funding.
- New enrollees in 2025 skewed younger, which shifts the expected plan-type distribution at renewal. Brokers should expect more Bronze and HDHP queries from this segment.
- A record enrollment year means a record renewal book. The broker who does not review their client list before November is ceding AOR ground to anyone who does.
Where the growth came from
Two policy changes drove the enrollment surge that started in 2022 and compounded through 2025. The American Rescue Plan eliminated the 400 percent FPL subsidy cliff, and the Inflation Reduction Act extended those enhanced subsidies through plan year 2025. Households that previously earned too much for meaningful APTC suddenly qualified for real premium reductions, and enrollment followed.
The second driver was less expected. When Congress ended Medicaid continuous enrollment in April 2023, states began redetermining eligibility for their Medicaid populations for the first time since 2020. A significant share of those redeterminations resulted in disenrollment, and many former Medicaid enrollees transitioned into Marketplace plans. CMS reported millions of new Marketplace enrollees in 2023 and 2024 who came directly from Medicaid redetermination. Those households renewed in 2024 and 2025, contributing to the base enrollment count.
For deeper context on the rule changes that shaped the 2026 enrollment landscape, read the CMS plan year 2026 rule changes summary.
Plan year 2025 vs 2024 at a glance
The table below summarizes key enrollment metrics across the two most recent plan years. These are based on CMS final OEP enrollment snapshots and broker-channel data from CMS enrollment reports.
| Metric | Plan year 2024 | Plan year 2025 | Note |
|---|---|---|---|
| Total Marketplace enrollment | ~21.4 million | ~24.2 million | Record high. CMS OEP final snapshot. |
| Broker-assisted enrollments | ~11 million | ~12.5 million | Approximately 52% of total. CMS enrollment data. |
| New-to-Marketplace enrollees | ~4.2 million | ~4.6 million | Includes Medicaid transition enrollees. |
| Automatic re-enrollments | ~7 million | ~7.8 million | Passive renewals without broker review. |
Figures are approximations based on CMS OEP final enrollment snapshots and interim reports. Broker-assisted share is derived from CMS enrollment data by channel. Confirm current figures at CMS.gov before citing.
The passive renewal problem at scale
Roughly 7.8 million enrollees in plan year 2025 renewed passively, meaning CMS automatically re-enrolled them in the same plan or the closest equivalent when their existing plan was discontinued. That number has grown every year alongside total enrollment.
Passive renewal is not broker-assisted renewal. A client who auto-renewed without an annual review call may be in the wrong metal tier, on a plan whose SLCSP benchmark changed, or receiving a different APTC amount than last year because the household income estimate was never updated. The broker who calls in October and runs the renewal quote is the one who catches those issues. The broker who waits for the client to call in February is fixing problems instead of preventing them.
Connecture workflows built around annual paper renewal packets were not designed for this kind of proactive outreach at scale. Brokers who moved to a faster quoting stack in 2024 or 2025 had the review call in 90 seconds rather than 20 minutes.
State-based exchanges and what they mean for broker registration
Fourteen states and Washington DC operate their own exchanges rather than using HealthCare.gov. In large SBE states, enrollment patterns look different from the federal platform: extended OEP windows of 30 to 45 days past January 15, higher broker-assisted shares in markets with strong navigator programs, and plan availability that diverges from what brokers see on the federal platform.
Brokers working clients in SBE states need a separate registration with each state exchange to be listed as broker of record. A client enrolled through Covered California, for example, cannot have a broker added via HealthCare.gov. For the registration and workflow differences, read state-based exchanges vs HealthCare.gov.
Who the new enrollees are and what they want
CMS age-band breakdowns from recent enrollment reports show the Marketplace getting younger. Enrollees under 35 grew as a share of total enrollment from 2022 through 2025. That shift has direct implications for the broker's product conversation.
Younger enrollees typically want the lowest net premium, which usually means Bronze. But that recommendation changes if the household is in the 100 to 250 percent FPL range where Silver CSR plans bring the out-of-pocket maximum down sharply. The enrollment surge did not change the Silver-first rule for subsidy-eligible households in the CSR income range. It just means more of those conversations are happening. For eligibility basics, read who qualifies for an ACA subsidy in 2026.
What plan year 2026 enrollment means for competition
A growing Marketplace is a growing prize. More enrollees means more clients who can be approached for a broker-of-record change by another agent. The AOR battle that existed at 16 million enrollees is more intense at 24 million because the population of reachable clients is 50 percent larger.
The defensive move is the October outreach call. Not a mass email. A call. A broker who reaches 80 percent of their book with a personal outreach before November 1 loses far fewer clients to AOR changes during AEP than a broker who sends a newsletter in late October and waits to hear back.
The 7.8 million passive auto-renewals in plan year 2025 represent clients who never talked to a broker that year. Some of those belong to brokers who simply did not call. Others are unrepresented. Both groups are reachable during AEP.
FAQ
Common questions brokers ask about ACA enrollment growth and what it means for the book.
Why did ACA enrollment grow so much between 2022 and 2025?
Two factors drove growth. First, the American Rescue Plan (2021) and the Inflation Reduction Act (2022) extended enhanced APTC eligibility above 400 percent FPL, bringing in households that previously received no subsidy or a minimal one. Second, the end of Medicaid continuous enrollment in April 2023 pushed millions of former Medicaid recipients into Marketplace plans as they were redetermined ineligible for Medicaid.
What percentage of Marketplace enrollees use a broker?
CMS enrollment data consistently shows brokers and agents assisting roughly half of all Marketplace enrollments. Broker-assisted enrollees tend to have lower voluntary disenrollment rates than direct-channel enrollees, which is one reason AOR disputes matter at renewal scale.
How do state-based exchange enrollment numbers compare to HealthCare.gov?
States with their own exchanges, including California, New York, and Massachusetts, report enrollment separately from CMS. California's Covered California consistently posts the largest SBE volume, often exceeding 1.5 million enrollees. New York and Massachusetts operate smaller exchanges with above-average broker-assisted shares. Brokers working clients in SBE states register separately with each exchange.
Does higher Marketplace enrollment mean more competition for brokers?
Yes. A larger enrolled population means more clients who already have Marketplace coverage and are reachable by other brokers at renewal. The broker-of-record change (BOR change) rate goes up in large enrollment years because there are simply more clients to target. The best defense is an October outreach sequence before AEP opens.
What happens to Marketplace enrollment if enhanced subsidies expire?
CBO and academic analyses of the ARP subsidy extensions have consistently projected enrollment drops in the range of 2 to 4 million if enhanced subsidies expire and return to pre-ARP levels. Brokers who serve clients above 400 percent FPL would see direct impact on those clients' net premium costs and some may leave the Marketplace. This is why the legislative renewal cycle matters to the broker book, not just to policymakers.
