HSA eligibility is defined by the IRS and depends on your health plan, insurance coverage, and age. This guide walks through the eligibility requirements for 2025 and 2026, including new updates under federal law, to help you understand who can open and contribute to an HSA and how contributions work over time.

Who can open a Health Savings Account in 2025?

To contribute to a Health Savings Account (HSA) in 2025, you must meet specific IRS rules. Here’s what that means:

• You must have a qualified High-Deductible Health Plan (HDHP). This is a health plan that meets yearly IRS limits for deductibles and out-of-pocket costs.

• You cannot have other disqualifying coverage, such as:

  • A general-purpose Flexible Spending Account (FSA)

  • Secondary insurance that pays for non-preventive care before you meet your deductible Note: Dental, vision, and limited-purpose FSAs are allowed.

• You can’t be enrolled in Medicare (Part A or B) or Medicaid.

• No one else can claim you as a dependent.

• You must be at least 18 years old.

All of these conditions must be met to make new HSA contributions. If you're unsure, check with your health plan administrator or tax advisor before contributing.

What are the new HSA eligibility rules for 2026?

Starting January 1, 2026, new federal rules will expand who is eligible to open and contribute to a health savings account. A new law called the One Big Beautiful Bill (OBBB) allows many ACA marketplace plans—like Bronze and Catastrophic plans—to count as HSA-eligible, even if they don’t meet the usual requirements. This change gives more people access to HSAs, especially those who were left out before because of how their plans were designed.

To be eligible in 2026, you'll need to meet the following requirements:

• You’re enrolled in an HSA-qualified plan. This now includes many ACA Bronze and Catastrophic marketplace plans starting in 2026.

• You don’t have disqualifying coverage, like a general-purpose FSA or extra insurance that pays for care before you hit your deductible.

• You’re not enrolled in Medicare (Part A or B) or Medicaid.

• You’re not claimed as a dependent on someone else’s tax return.

• You’re 18 or older.

This update makes HSAs available to more people with individual or marketplace health plans—especially freelancers, small-business workers, or people who retire early. To learn more about the recent changes, review our guide on the new HSA rules under the OBBB.

What makes a health plan HSA-eligible in 2025 and 2026?

To contribute to an HSA, you must be covered by a qualifying High-Deductible Health Plan (HDHP). Each year, the IRS updates what qualifies based on deductible and out-of-pocket limits.

For 2025:

• Minimum deductible: $1,650 (self-only) / $3,300 (family)

• Maximum out-of-pocket: $8,300 (self-only) / $16,600 (family)

For 2026:

• Minimum deductible: $1,700 (self-only) / $3,400 (family)

• Maximum out-of-pocket: $8,500 (self-only) / $17,000 (family)

To qualify:

• You must pay for medical services out of pocket until you meet your deductible. This includes prescriptions.

• Preventive care (like annual checkups) is exempt and must be covered by your plan without cost-sharing.

• If you have family coverage (a plan that covers you and at least one other person), it must meet the higher deductible and out-of-pocket limits set by the IRS.

Your plan must meet all these rules to be considered HSA-eligible.

What happens once you're eligible?

Once you meet the IRS rules for HSA eligibility, you can open and contribute to a Health Savings Account. You own the account—not your employer or insurance company—so it stays with you even if you change jobs, health plans, or retire.

The IRS sets yearly limits on how much you (and others on your behalf) can contribute. These limits apply to the total of all contributions, including from an employer, spouse, or direct deposit. If you're 55 or older, you can make an additional $1,000 “catch-up” contribution each year. For current HSA contribution rules and tax details, see our HSA Tax Guide.

HSA funds can be used tax-free for qualified medical expenses at any time. There's no deadline to spend your balance, and unused money rolls over year to year.

Just remember: if you use HSA funds for anything other than a qualified expense, you could face taxes and penalties. For a full list of eligible items, check out our Eligible Expenses Guide.

What happens if I lose HSA eligibility?

Life changes, like switching jobs or enrolling in Medicare, can affect your HSA eligibility. Here's what to know:

• You still own your HSA. The funds remain yours, and you can continue using them for qualified expenses at any time.

• You must stop contributing. Once you're no longer eligible, you can’t add new funds—but you can resume contributions later if you regain eligibility.

• You can roll or retain your account. If you change employers, you may roll your HSA into a new one or keep multiple accounts.

Maintaining eligibility helps you grow your HSA tax-free. If you're unsure about your current status, check with your health plan administrator or a tax professional.

Still not sure if you're eligible?

HSA eligibility can get complicated—especially if you have mixed coverage, a spouse with benefits, or use an FSA. To learn more about how health savings accounts work, check out our HSA Guide. If you're unsure about eligibility, consult with a benefits specialist before contributing.

If you're ready to open an HSA or want to learn more, contact our team to get started.