IRS Releases 2027 ACA
Pay-or-Play Penalties

The IRS recently announced 2027 ACA pay-or-play penalty amounts. For 2027, the adjusted “A” penalty will increase to $3,780 (up from $3,340 in 2026) and the adjusted “B” penalty will increase to $5,670 (up from $5,010 for 2026). ACA pay-or-play penalties are adjusted annually based on inflation figures, and increased inflation has led to larger than average increases.

Under the ACA, employers with 50 or more full-time (or full-time equivalent) employees must provide full-time employees and their dependents with access to affordable, minimum-value health coverage or risk a potential penalty. The employer may be faced with a penalty under subsection A or B of the ACA penalty provisions if at least one full-time employee receives a subsidy for coverage in the Exchange.

The A penalty is applicable to employers who do not offer minimum essential coverage to substantially all of their full-time employees, and at least one full-time employee obtains a subsidy in the Exchange. The A penalty is calculated based on the total number of full-time employees, even if only one employee receives a subsidy. For 2027, the monthly penalty will be one-twelfth of $3,780 times the number of full-time employees minus 30.

The larger B penalty applies to an employer who has offered minimum essential coverage (even if not affordable or minimum value) to substantially all of its employees and is calculated based on the number of full-time employees who receive a subsidy. For 2027, the monthly penalty will be one-twelfth of $5,670 times the number of subsidized employees.

Please visit www.moreton.com/news-events/ for more information and to view other client alerts. This Client Alert was written by Carolyn Cox, who provides our clients with compliance services. For additional questions, please contact Carolyn at 801-715-7110 or [email protected].
© 2026 by Moreton & Company. This Client Alert is intended to alert recipients to recent legal developments. It does not constitute the rendering of legal advice or recommendations and is provided for your general information only. If you need legal advice, you must seek an opinion from your attorney.