The SHOP Marketplace (Small Business Health Options Program) was built under the Affordable Care Act so employers with generally 1 to 50 employees could offer group coverage and claim a tax credit. Congress's budget office once projected 4 million people in SHOP by 2017. CMS reported about 27,000 employers and nearly 230,000 people actually enrolled nationwide in January 2017, and in 2018 HealthCare.gov stopped enrolling employers online. A small employer searching for SHOP in 2027 therefore needs a straight answer about what is still available.
Small employers will find below who qualifies for SHOP for 2027, where SHOP plans exist, the 2026 small business health care tax credit, and the options most small employers use instead: a QSEHRA or an ICHRA. Employees who get an individual-coverage allowance shop on the individual Marketplace, which is open for 2027 coverage from November 1, 2026 to January 15, 2027. For the employee view of an offer, see HRA offered by an employer, ICHRA and QSEHRA.
Coverage Breakdown
Direct answer: does a small employer qualify for the SHOP Marketplace in 2027?
It depends. SHOP, the Small Business Health Options Program, is generally for employers with 1 to 50 employees, but HealthCare.gov no longer enrolls employers online and SHOP plans are scarce outside state-run marketplaces. For 2027, small employers without a SHOP plan usually choose a private small-group plan, a QSEHRA (under 50 full-time equivalent employees), or an ICHRA (any size). The small business tax credit requires SHOP coverage.
Who qualifies for the SHOP Marketplace (2027)
HealthCare.gov says a small employer that can offer SHOP coverage is generally one with 1 to 50 employees, and it provides a full-time equivalent (FTE) calculator for counting staff. A small group is defined as 50 or fewer employees under federal law, though a few states have used a 100-employee limit (Vermont, New York and California, with Colorado moving to 50 in 2026, according to healthinsurance.org). Employers with 50 or more FTEs are also treated as applicable large employers under the ACA employer mandate, which is a separate rule from SHOP eligibility.
Eligibility also depends on location, because a SHOP plan must exist where the business is based. The 2027 individual Marketplace is open from November 1, 2026 to January 15, 2027, but SHOP is a separate small-group program with its own plans and dates, so ask a SHOP-registered broker or the carrier for the effective-date options in your area. A business in a state with no SHOP carrier cannot create one by applying, which is why the next section shows where plans exist. Tax-credit eligibility is a separate test from SHOP eligibility and is explained after that.
Where SHOP plans exist and how employers enroll (2027)
In states that use HealthCare.gov, employers do not enroll online. CMS changed the process for plans starting on or after January 1, 2018: employers enroll directly with an insurance company offering SHOP plans or through an agent or broker registered with the federal SHOP, and still get an eligibility determination on HealthCare.gov. HealthCare.gov publishes SHOP plan data files for 2027 for states where the federal government operates SHOP, so those files show which carriers still sell.
A healthinsurance.org tally posted September 23, 2025 found SHOP-certified medical plans in only six HealthCare.gov states: Alabama, Montana, New Hampshire, Ohio, Wisconsin and Wyoming, from five insurers. The same tally lists state-run small business platforms in California, Colorado, Connecticut, the District of Columbia, Georgia, Idaho, Kentucky, Maine, Maryland, Massachusetts, New Jersey, New York, Oregon, Rhode Island, Vermont and Virginia, and says Washington, Minnesota, New Mexico and Nevada no longer have SHOP plans. That count predates the 2027 plan year, so confirm current carriers with a broker.
Small business health care tax credit rules (tax year 2026)
The federal small business health care tax credit pays up to 50 percent of premiums for small business employers and up to 35 percent for small tax-exempt employers, for two consecutive taxable years. For tax year 2026, an eligible employer has fewer than 25 FTEs, pays at least 50 percent of the cost of employee-only coverage, and has average annual wages of no more than $68,200, which is twice the $34,100 dollar amount in IRS Rev. Proc. 2025-32. The credit shrinks above 10 FTEs and above $34,100 average wages in 2026. Employers calculate it on Form 8941.
The IRS requires that the employer offer a qualified health plan through a SHOP Marketplace, or qualify for a limited exception. Because a QSEHRA, an ICHRA and an off-exchange small-group plan are not SHOP coverage, none of them earns this credit. Healthinsurance.org reports that an employer whose two-year window began on a SHOP plan can keep the credit after switching to a non-SHOP plan under IRS Notice 2018-27, and a first-time claimant can claim it only if SHOP plans are available in its area. Ask a tax professional before relying on either point.
Why small employers move to an ICHRA or QSEHRA instead of SHOP (2027)
Small employers who cannot find a SHOP plan commonly turn to a health reimbursement arrangement, which puts staff on individual ACA-compliant Marketplace plans that include the essential health benefits and cannot turn away people for a preexisting condition. An ICHRA (individual coverage HRA) can be offered by employers of any size, with no federal minimum or maximum allowance. A QSEHRA is limited to employers under 50 full-time equivalent employees that offer no group plan, with 2026 limits of $6,450 self-only and $13,100 family. The IRS had not published 2027 QSEHRA limits as of November 6, 2026.
Staff effects matter. For plan years beginning in 2027, an ICHRA or QSEHRA offer is affordable when the lowest-cost Silver plan, after the allowance, costs no more than 10.22% of the employee's household income (Rev. Proc. 2026-26). An affordable offer ends the employee's Marketplace premium tax credit, while an unaffordable ICHRA lets the employee choose the ICHRA or the credit, never both. Employees newly offered an ICHRA generally get a Special Enrollment Period beginning 60 days before the allowance starts.
Alternatives if SHOP is not available to your business (2027)
Small employers without a usable SHOP plan have four concrete alternatives for 2027, summarized in the table below. Employers should compare options before the plan year starts, because a late ICHRA or QSEHRA start pushes back when staff can use the allowance. Each can be arranged through a licensed broker, and employees who join the individual Marketplace shop at HealthCare.gov, where Open Enrollment for 2027 coverage runs from November 1, 2026 to January 15, 2027, with a December 15 deadline for coverage that starts January 1.
- ICHRA: any employer size, no federal allowance limit, staff buy individual plans.
- QSEHRA: employers under 50 full-time equivalent employees, 2026 limits $6,450 self-only and $13,100 family.
- Private small-group plan: bought from a carrier or broker outside SHOP, no small business tax credit.
- State-run small business exchange: available in states such as California, Colorado, Connecticut, New York and Oregon.
How a small employer applies and next steps (2027)
A small employer starts at HealthCare.gov's small business page, uses the FTE calculator, and then checks whether SHOP plans are sold in its county. If none are, the employer chooses among the alternatives above. For an ICHRA or QSEHRA, the employer sets the allowance and must give eligible employees written notice before the allowance starts. Staff then compare 2027 individual plans, with the exact premium tax credit depending on household income measured against the 2026 poverty guidelines ($15,960 to $63,840 for one person, 2027 coverage).
Frequently Asked Questions
Who qualifies for the SHOP Marketplace in 2027?
HealthCare.gov says SHOP is generally for employers with 1 to 50 employees, counted as full-time equivalents. A few states have allowed up to 100. A SHOP plan must also be sold where the business is based, and HealthCare.gov lists SHOP data for 2027 only for states where the federal government operates SHOP.
Can I still enroll in SHOP on HealthCare.gov?
Not online in most cases. For plans starting on or after January 1, 2018, CMS directed small employers in HealthCare.gov states to enroll through an insurance company offering SHOP plans or a SHOP-registered agent or broker, with the eligibility determination still made on HealthCare.gov. State-run SHOPs set their own enrollment process.
Is SHOP available in every state in 2027?
No. A healthinsurance.org tally posted September 23, 2025 found SHOP-certified plans in six HealthCare.gov states (Alabama, Montana, New Hampshire, Ohio, Wisconsin, Wyoming) plus state-run platforms in 16 jurisdictions. Washington, Minnesota, New Mexico and Nevada reportedly have none. Confirm 2027 carriers with a broker.
What does the small business health care tax credit pay in 2026?
For tax year 2026, the credit covers up to 50 percent of premiums for small business employers and up to 35 percent for small tax-exempt employers, for two consecutive years. The employer needs fewer than 25 FTEs, average annual wages of no more than $68,200, and at least 50 percent of employee-only premiums paid.
Does an ICHRA or QSEHRA qualify for the small business tax credit?
No. The IRS requires that the employer offer a qualified health plan through a SHOP Marketplace, or qualify for a limited exception. An ICHRA, QSEHRA or off-exchange group plan is not SHOP coverage, so employers weigh the tax credit (up to 50 percent of premiums, tax year 2026) against the simplicity of an HRA.
What are the QSEHRA limits for 2027?
The IRS had not published 2027 QSEHRA limits as of November 6, 2026. The 2026 limits are $6,450 for self-only coverage and $13,100 for family coverage (Rev. Proc. 2025-32). A QSEHRA is limited to employers under 50 full-time equivalent employees that offer no group health plan.
Do my employees lose Marketplace subsidies if I offer an ICHRA in 2027?
It depends on affordability. For plan years beginning in 2027, an ICHRA is affordable when the lowest-cost Silver plan, after the allowance, costs no more than 10.22% of the employee's household income. An affordable offer ends the premium tax credit; an unaffordable one lets the employee choose the ICHRA or the credit, never both.
Do I have to offer health insurance if I have fewer than 50 employees?
No. The ACA employer shared responsibility rules apply to applicable large employers, which generally means 50 or more full-time employees including full-time equivalents. A business under that size faces no federal penalty for not offering coverage, but it may choose SHOP, a group plan, a QSEHRA or an ICHRA.
