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Is a Bronze or Catastrophic Plan HSA-Eligible for 2027?

Short answer: Per IRS Notice 2026-5, for months beginning after December 31, 2025, a bronze or catastrophic plan that is available as individual coverage through an Exchange is treated as a high deductible health plan (HDHP) for HSA purposes, even if its deductible or out-of-pocket maximum would not otherwise meet the HDHP numbers. HealthCare.gov says all Bronze and Catastrophic plans work with Health Savings Accounts. Other eligibility conditions still apply (see below).

What changed

Public Law 119-21 (July 4, 2025) amended section 223 so the HDHP definition includes bronze (ACA section 1302(d)(1)(A)) and catastrophic (section 1302(e)) plans available as individual coverage through an Exchange. Before that, many bronze plans did not qualify, and catastrophic plans could not.

Key points from Notice 2026-5 (Q&A 4 to 9)

• On-Exchange plans: treated as HDHPs from 2026 (A-4).
• Bought off-Exchange: treated as an HDHP if the same plan is available on an Exchange (A-6). If you enroll in such a plan and have no reason to believe it is not available on an Exchange, the IRS treats you as an eligible individual (A-7).
• Employer ICHRA/QSEHRA used to buy the plan: does not by itself stop the plan being an HDHP (A-5), but an HRA generally must reimburse only premiums to avoid disqualifying you.
• Bronze plan variants with higher actuarial value (for example due to de minimis variance) are still treated as HDHPs (A-9).

Catastrophic plan access

Notice 2026-5 describes catastrophic plans as limited to people under 30 before the plan year, or people exempt under section 5000A because of lack of affordable coverage or hardship.

Finding plans on HealthCare.gov

When you preview or shop plans, HealthCare.gov says to filter for "HSA-eligible" or look for it in plan details. It also says to contact your insurer to confirm whether a plan qualifies.

Other things that still matter

• You generally can't contribute to an HSA if you have other disqualifying coverage, such as a general-purpose health FSA (see FSA and HSA together).
• Medicare enrollment ends your ability to contribute (see mistakes).
• Contribution limits for 2027: HSA limits 2027.

Dates

HealthCare.gov (as read October 17, 2026): Open Enrollment starts November 1; December 15 is the last day to enroll or change plans for coverage starting January 1; January 15 is the last day of Open Enrollment, with coverage starting February 1 for sign-ups from December 16 through January 15 (first premium paid). Your state's Marketplace may differ; we did not verify state-by-state dates.

FAQ

Is a Silver plan HSA-eligible? Only if it meets the HDHP deductible and out-of-pocket rules (the HealthCare.gov page says plans in other categories may be eligible depending on those numbers).

Does eligibility start when I enroll? HSA eligibility is determined month by month; see the proration page.

Can I open the HSA before coverage starts? Expenses before you establish your HSA aren't qualified (Pub. 969); details depend on state law.

What we could not verify

• Your specific plan's status (confirm with the insurer and HealthCare.gov filter).
• State-based Marketplace dates.
• Any later IRS guidance after October 17, 2026.

Sources (official)

• IRS, Notice 2026-5 (OBBBA changes: bronze/catastrophic plans, telehealth, direct primary care) — https://www.irs.gov/pub/irs-drop/n-26-05.pdf (read October 17, 2026)
• HealthCare.gov, Health Savings Account (HSA)-eligible plans — https://www.healthcare.gov/high-deductible-health-plan/hdhp-hsa-information/ (read October 17, 2026)
• HealthCare.gov, Key dates and deadlines — https://www.healthcare.gov/quick-guide/dates-and-deadlines/ (read October 17, 2026)
• IRS, Publication 969 (2025), Health Savings Accounts and Other Tax-Favored Health Plans (Feb 11, 2026 print; for 2025 returns) — https://www.irs.gov/publications/p969 (read October 17, 2026)

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Not tax/financial advice. Examples use made-up figures and have not been reviewed by a tax professional. See the disclosure.