The change is especially important for people entering the Health insurance field ahead of Open Enrollment. State licensing and federal Marketplace registration are separate processes, so new agents can continue the licensing process even if they cannot immediately register to assist consumers through the federal Marketplace.
What Did CMS Change for ACA Marketplace Agents?
The Centers for Medicare & Medicaid Services (CMS) temporarily paused Plan Year 2027 registration for agents and brokers who did not have an active Plan Year 2026 Exchange Agreement with CMS when the moratorium took effect on September 22, 2026.
The moratorium applies to registration with the federally facilitated Exchanges, which includes:
- Federally facilitated Exchanges (FFEs)
- State-Based Exchanges on the Federal Platform (SBE-FPs)
Affected agents and brokers cannot complete the applicable Plan Year 2027 Exchange agreements until the moratorium ends.
The moratorium is scheduled to remain in effect through February 1, 2027. CMS may end it earlier, extend it, or otherwise modify it through a subsequent Federal Register notice.
State insurance licensing has not been paused.
Who Is Affected by the ACA Agent Registration Moratorium?
The moratorium primarily affects agents and brokers entering the federal Marketplace for the first time or returning without a Plan Year 2026 Exchange agreement.
If an agent or broker did not have a Plan Year 2026 Exchange agreement with CMS as of September 22, 2026, that person generally cannot complete Plan Year 2027 registration with the federally facilitated Exchanges while the moratorium is in effect.
Agents and brokers who had Plan Year 2026 Exchange agreements can continue through the applicable Plan Year 2027 registration process and must meet CMS requirements for the new plan year.
The rule also does not affect agents and brokers registering directly with State-Based Exchanges that operate outside the federal platform.
Can You Still Get a Health Insurance License?
Yes. The CMS moratorium does not prevent someone from obtaining a state Health or Life & Health insurance license.
State insurance departments regulate producer licensing. The requirements vary by state but may include:
- Completing required pre-licensing education
- Passing the state insurance licensing exam
- Completing fingerprinting or a background check
- Applying for the insurance license
- Meeting other state-specific licensing requirements
A state insurance license and federal Marketplace registration are separate.
A Health insurance license gives the producer the state authority associated with that license. Agents who want to assist consumers through the federally facilitated ACA Marketplace must also complete the applicable CMS registration and training requirements.
Insurance licensing requirements vary by state. Review the state-specific licensing requirements for the education, exam, application, and other requirements that apply in each state.
Can New Health Insurance Agents Still Sell Insurance?
Yes. The CMS moratorium applies to affected federal Marketplace registrations, not to the Health insurance license itself.
Depending on the agent’s state licensing authority, carrier appointments, certifications, and other requirements, a Health insurance producer may be able to work with products such as:
- Employer and group health insurance
- Individual health coverage sold outside the Marketplace where available
- Dental and vision insurance
- Accident and supplemental health insurance
- Disability income insurance
- Medicare-related products after meeting applicable licensing, certification, carrier, and federal requirements
- Other health insurance products authorized by the producer’s license
An agent’s ability to sell a particular product depends on the state, license authority, carrier appointment, and any product-specific requirements.
For agents planning specifically to sell ACA plans through HealthCare.gov or another federally facilitated Exchange, however, the moratorium can prevent a newly entering agent from completing the registration needed to assist consumers during the upcoming Open Enrollment Period.
Does the Moratorium Apply to Medicare Agents?
No. The September 2026 moratorium concerns agent and broker registration for the ACA Health Insurance Marketplace.
It does not pause state licensing or the separate process for becoming authorized to sell Medicare-related insurance products.
Agents selling Medicare Advantage or Medicare Part D products must continue to meet the licensing, training, certification, carrier, and CMS requirements that apply to those products.
ACA Marketplace registration and Medicare certification are separate processes.
What About Agents Who Were Registered for 2026?
Agents and brokers with applicable Plan Year 2026 Exchange agreements are not blocked by the new-registration moratorium simply because they are registering for Plan Year 2027.
They must still complete the applicable Plan Year 2027 registration and training requirements.
CMS also announced additional safeguards for agents and brokers participating in the federal Marketplace, including:
- Requiring existing agents and brokers to complete identity proofing again through Login.gov or ID.me
- Requiring applications involving an agent or broker to include verifiable Social Security numbers or immigration document numbers for non-newborn applicants
- Preventing agents and brokers from being added to applications that consumers are required to complete themselves through HealthCare.gov
- Requiring electronic consumer authorization before an agent or broker can act on an application or enrollment
Agents participating in the Marketplace should review the latest CMS Marketplace registration and training requirements for Plan Year 2027.
Why Did CMS Pause New ACA Marketplace Agent Registrations?
CMS says the moratorium is part of its effort to address unauthorized enrollments, unauthorized plan changes, misuse of consumer information, and other Marketplace compliance problems.
CMS reported that agents and brokers who first registered for Plan Year 2026 represented about 11% of registered agents and brokers with at least one active federal Marketplace enrollment, but accounted for approximately 30% of the 569 agents and brokers who received Notices of Intent to Terminate Exchange agreements in July and August 2026.
CMS concluded that additional safeguards were needed before continuing to register new agents and brokers for Plan Year 2027.
Those safeguards include additional identity verification, authentication, monitoring, and consumer authorization controls.
How Many New Agents Could the Moratorium Affect?
CMS estimates that approximately 19,982 agents and brokers would have registered during the period covered by the moratorium without the restriction.
CMS also estimates that approximately 6,956 of those agents and brokers could have had at least one active enrollment during Open Enrollment, based on Plan Year 2026 activity.
Because Marketplace Open Enrollment runs from November 1 through January 15, the moratorium overlaps the period when many agencies recruit and onboard new ACA agents. Agencies that planned to license and register new producers specifically for Open Enrollment may need to adjust how those producers are used during the 2027 enrollment season.
Does the Moratorium Apply in Every State?
No.
The rule applies to the federally facilitated Exchanges, including State-Based Exchanges on the Federal Platform.
It does not affect agent and broker registration directly through State-Based Exchanges that operate their own enrollment platforms.
Because states use different Marketplace structures, an agent should confirm which Exchange operates in the state where the agent plans to assist consumers.
What Should New Insurance Agents Do Now?
If you are already working toward a Health or Life & Health insurance license, the CMS moratorium does not require you to stop the state licensing process.
After becoming licensed:
- Confirm which Health insurance products the license authorizes in your state
- Determine which Marketplace platform the state uses
- Ask the agency or carrier which products and markets you will work with
- Complete any required carrier appointments, product certifications, or additional training
- Follow CMS updates if your role will involve the federal ACA Marketplace
CMS has stated that the moratorium may be ended early, extended, or otherwise modified, so agents planning to participate in the Marketplace should continue checking for updated federal guidance.
Frequently Asked Questions
Did CMS stop issuing Health insurance licenses?
No. State insurance departments issue producer licenses. The CMS moratorium affects certain agent and broker registrations with the federally facilitated ACA Marketplace, not state Health insurance licensing.
Can I still take the Health insurance licensing exam?
Yes. The CMS moratorium does not affect state insurance examinations or licensing requirements. You can continue completing the licensing process required by your state, including pre-licensing education and the state exam where applicable.
Can I still get a Life & Health insurance license?
Yes. The moratorium does not prevent someone from completing state requirements for a Life & Health insurance license. It only affects certain registrations to participate in the federally facilitated ACA Marketplace.
Can a newly licensed agent sell ACA Marketplace plans during 2027 Open Enrollment?
A newly licensed agent who did not have a Plan Year 2026 Exchange agreement generally cannot complete Plan Year 2027 registration with the federally facilitated Exchanges while the moratorium remains in effect.
The moratorium is scheduled to continue through February 1, 2027 unless CMS ends, extends, or modifies it.
Does the ACA agent moratorium apply to State-Based Exchanges?
The moratorium does not affect registrations directly through State-Based Exchanges.
However, State-Based Exchanges on the Federal Platform are included in the federally facilitated Exchange registration system covered by the moratorium.
Does the moratorium affect existing ACA Marketplace agents?
Agents and brokers with applicable Plan Year 2026 Exchange agreements are not subject to the new-agent registration pause in the same way as agents without a 2026 agreement. They still must complete applicable Plan Year 2027 registration and training requirements.
Is the ACA Marketplace registration moratorium permanent?
No. The current moratorium took effect September 22, 2026 and is scheduled to end February 1, 2027.
CMS can end it earlier, extend it, or otherwise modify it through a subsequent notice.
Does the moratorium affect Medicare agents?
No. The moratorium concerns ACA Marketplace registration. Medicare-related insurance has separate licensing, certification, carrier, and federal requirements.
Prepare for a Health or Life & Health Insurance License
The ACA Marketplace registration moratorium does not change state insurance licensing requirements.
National Online Insurance School provides state-specific online insurance licensing courses and exam preparation for prospective Life & Health insurance agents. Where pre-licensing education is required, the course satisfies the applicable education requirement while helping students prepare for the state insurance exam.
