Open Enrollment Starts Nov. 1: What Small Employers Need to Know

Picture the owner of a six-person landscaping company, sitting in her truck at the end of a long day. Her phone lights up with a text from her crew lead: “Are we getting health insurance next year?”

She does not have an answer yet. She knows coverage is expensive, she has heard of the Marketplace, and she suspects there is a deadline coming. She is right about that.

Open enrollment for 2027 health plans starts Nov. 1. Here is what small employers like her need to know, and what they can do in the next few weeks.

When does open enrollment for 2027 health plans start?

Open enrollment on the federal Health Insurance Marketplace begins Sunday, Nov. 1, 2026. HealthCare.gov’s dates and deadlines page lays out three dates that matter:

• Nov. 1: the first day to enroll in, renew or change a Marketplace plan for 2027.
• Dec. 15: the last day to pick a plan for coverage that starts Jan. 1.
• Jan. 15, 2027: open enrollment ends. Plans chosen between Dec. 16 and Jan. 15 start Feb. 1, once the first premium is paid.

Those are the dates for HealthCare.gov. States that run their own marketplaces can set different windows, so employees in those states should check their state’s site.

Open enrollment is mainly for individuals and families. But it shapes decisions for small employers, too, because many small-business workers buy their own coverage, and the most common ways small companies help pay for health care tie directly into the Marketplace.

Why does open enrollment matter to a small employer?

A business with fewer than 50 full-time employees, counting full-time equivalents, is not subject to the federal employer coverage requirement, according to the IRS. That leaves three common paths: offer a small-group plan, reimburse employees for individual coverage through a health reimbursement arrangement, or offer nothing and let workers shop on their own.

Each choice affects what your employees see when they log in on Nov. 1. A reimbursement arrangement can change whether a worker qualifies for a premium tax credit. A group plan can make Marketplace shopping unnecessary. Knowing your plan before employees start comparing options saves confusion later.

What is SHOP, and can a small business join any time?

SHOP, the Small Business Health Options Program, is the Marketplace channel for employer plans. According to CMS’s SHOP page, it is generally open to employers with 1 to 50 full-time-equivalent employees, and up to 100 in some states. Employers must offer coverage to all full-time employees, generally those working 30 or more hours a week, and need an office or work site in the state.

Unlike individual open enrollment, SHOP coverage can start any month of the year. Businesses enroll through an insurance company or a SHOP-registered agent or broker, as HealthCare.gov’s small-business page explains.

There is one seasonal wrinkle worth circling on the calendar. In many states, at least 70% of employees offered coverage must accept it or have other coverage. CMS says employers that apply or renew between Nov. 15 and Dec. 15 can enroll without meeting that participation requirement. For a very small team where a few people already have coverage through a spouse, that window can make a group plan possible.

Who qualifies for the small business health care tax credit?

Buying through SHOP is also the route to a federal tax credit. The IRS explains that the Small Business Health Care Tax Credit can cover up to 50% of premiums paid by small businesses and up to 35% for small tax-exempt employers. To qualify, an employer generally must:

• Have fewer than 25 full-time-equivalent employees.
• Pay average annual wages below an inflation-adjusted limit set by the IRS.
• Offer a qualified health plan through SHOP, or meet a limited exception.
• Pay at least 50% of the cost of employee-only coverage.

The credit is available for two consecutive tax years. Because the rules on wages and full-time equivalents are technical, have a tax professional run the numbers before counting on it.

How do QSEHRAs and ICHRAs work with Marketplace plans?

Health reimbursement arrangements let an employer give workers a tax-advantaged allowance to buy their own insurance, often on the Marketplace. HealthCare.gov’s HRA guide describes two main types.

QSEHRA

A Qualified Small Employer HRA is for employers with fewer than 50 employees that do not offer a group health plan. The employer chooses how much to contribute, up to an annual cap that adjusts with inflation. For 2026, the cap is $6,450 for an individual and $13,100 for a household. Employees must have qualifying individual coverage.

ICHRA

An individual coverage HRA, which HealthCare.gov now calls a CHOICE Arrangement, is open to employers of any size with at least one employee. There is no annual maximum, and the employer can extend it to dependents. Employees must have individual health coverage.

Notice rules and tax credits

Both types generally require written notice to employees 90 days before the plan year starts. That means an employer hoping to launch an arrangement on Jan. 1 is already past the usual notice point and should ask an adviser about timing, or plan a later start date.

Both also interact with premium tax credits. If an arrangement is considered affordable for an employee, that employee generally cannot get a premium tax credit for Marketplace coverage. Workers who newly gain access to either type qualify for a special enrollment period to buy individual coverage, so they are not locked into the Nov. 1 to Jan. 15 window.

What should small employers do before Nov. 1?

1. Decide your approach for 2027. Group plan, reimbursement arrangement or neither. Write it down so you can answer employees clearly.
2. Tell employees what you are offering. If you offer nothing, say so, and point them to HealthCare.gov or your state’s marketplace and the Dec. 15 deadline for Jan. 1 coverage.
3. Flag Nov. 15 to Dec. 15 if a group plan is on the table. That is when many states waive the 70% participation rule for SHOP.
4. Budget the cost. Health benefits are a fixed monthly expense that does not shrink in a slow month. Our explainer on reading real profit instead of your bank balance can help you test whether the business can carry it.
5. Talk to a licensed professional. A SHOP-registered broker and a tax professional can check eligibility, affordability and credit rules for your situation. This article is general information, not advice for any specific business.

Health coverage is one of several year-end decisions competing for attention. Our list of Q4 moves for small businesses covers others worth finishing before the calendar turns.

What if a small business cannot afford coverage this year?

Plenty of small employers are in that spot. Even without offering a plan, an owner can help by sharing the key dates, giving workers time to research options, and pointing them to HealthCare.gov’s tools for checking whether they qualify for savings based on income. It costs nothing and can make the season less stressful for the team.

For the landscaping company owner reading that text from her crew lead, the honest answer might not be “yes” this year. It can still be a clear plan: a date on the calendar, a broker call booked and a straight answer for the crew before Dec. 15.

Frequently asked questions

Do small businesses have to offer health insurance?

Under federal rules, employers with fewer than 50 full-time employees, including full-time equivalents, are not subject to the employer coverage requirement. Many still choose to, through a group plan or a health reimbursement arrangement, to attract and keep workers. A licensed broker or tax professional can confirm how the rules apply to your business.

Can a small business enroll in SHOP outside open enrollment?

Yes. CMS says SHOP coverage can start any time of the year. In many states, employers that apply or renew between Nov. 15 and Dec. 15 can enroll without meeting the usual minimum participation requirement.

What is the deadline to enroll for coverage starting January 1, 2027?

On HealthCare.gov, the deadline is Dec. 15, 2026. Plans chosen between Dec. 16 and Jan. 15, 2027, generally start Feb. 1. States with their own marketplaces may use different dates.

What is the difference between a QSEHRA and an ICHRA?

A QSEHRA is limited to employers with fewer than 50 employees that do not offer a group plan, and it has an annual contribution cap. An ICHRA, which HealthCare.gov now calls a CHOICE Arrangement, is open to employers of any size and has no annual maximum.

Can employees with an HRA still get Marketplace subsidies?

It depends on whether the arrangement is considered affordable. If it is affordable, the employee generally cannot get a premium tax credit. If it is not, the employee may qualify for some help, so it is worth checking with a broker or tax professional.

Sources

• HealthCare.gov: A quick guide to the Health Insurance Marketplace (dates and deadlines)
• CMS: Small Business Health Options Program (SHOP)
• HealthCare.gov: SHOP coverage for small businesses
• HealthCare.gov: HRA guide for small businesses
• IRS: Determining if an employer is an applicable large employer
• IRS: Small Business Health Care Tax Credit and the SHOP Marketplace

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