ICHRA Statistics & 2025 Adoption Trends

ICHRA adoption is growing at a triple-digit pace

Since ICHRA became available in 2020, adoption has risen by more than 1,000%, according to the HRA Council. The most recent year continued the trend: small-employer ICHRA adoption grew 52% year over year among the Council''s longest-tenured ("Founding") members, and 18% across the aggregated member sample.

Total ICHRA and QSEHRA adoption across employers of all sizes rose 19% in the aggregated data and 27% among Founding Members — a sign that growth is broad, not concentrated in a single cohort.

Large employers are now the fastest-growing adopters

ICHRA started as a small-business tool, but the fastest growth is now among Applicable Large Employers (50+ full-time-equivalent employees). ALE ICHRA adoption rose 34% year over year, with the sharpest gains in the mid-market.

• 50–99 employees: +44%
• 100–199 employees: +49%
• 200+ employees: +31%
• Still, the majority of adopters are businesses with 20 or fewer employees.

For most adopters, it''s their first health benefit

ICHRA is largely bringing new coverage to the market rather than replacing existing plans. Among employers whose prior-year benefit is known, 83.5% had offered no health coverage at all before adopting an ICHRA or QSEHRA, while only 16.5% moved over from a traditional group plan.

In other words, ICHRA functions as an on-ramp — helping small businesses offer benefits for the first time, not just swapping one plan type for another.

Employers stick with HRAs once they adopt

Retention is strong. More than 9 out of 10 employers offering an ICHRA or QSEHRA in 2025 were renewing an arrangement from a prior year. The HRA Council notes that employers may shop among platforms, but they keep the HRA model regardless of which provider they choose — pointing to durable satisfaction rather than churn.

How many people are covered

Based on the Council''s aggregated sample, more than 260,000 U.S. employees were offered ICHRA or QSEHRA coverage for plan year 2025 — and because this is a members-only sample, the true market is meaningfully larger.

Dependent enrollment is climbing too: the dependent-to-subscriber ratio reached 0.67 in 2025, up from 0.11 in 2020, and now roughly on par with traditional group plans.

What plans employees actually choose

Given a defined allowance and the full individual market, employees tend to choose richer coverage than many expect. Nearly 70% selected a Gold or Silver plan for 2025.

• Gold: 35%
• Silver: 33.7%
• Bronze: 27.2%
• Medicare: 1.8%
• Platinum: 1.6%
• Catastrophic: under 1%

A younger, lower-risk pool

Employees aged 18–44 make up the largest share of ICHRA and QSEHRA enrollment. The HRA Council highlights that this historically lower-risk, lower-cost population entering the individual market helps stabilize the risk pool — supporting premium consistency and broader affordability over time.

QSEHRA continues to grow alongside ICHRA

While ICHRA has grabbed the headlines, QSEHRA — the capped version for employers under 50 — has still doubled in adoption since 2020. Both models of defined-contribution health benefits are proving durable, giving small employers two viable tax-advantaged paths.

Policy momentum is bipartisan

ICHRA has attracted support across the aisle at both the federal and state levels. As of mid-2025, Congress was considering codifying ICHRA in statute as the Custom Health Option and Individual Care Expense (CHOICE) arrangement.

States are moving too: Indiana became the first to enact an employer tax credit for ICHRA and QSEHRA adoption (up to $10 million a year), and Ohio (HB 133), Georgia (HB 341), and Texas (SB 1949) introduced their own incentive bills in 2025.

About this data

All figures on this page come from the HRA Council''s "Growth Trends for ICHRA & QSEHRA, Vol. 4 (2024–2025)." The report is built from voluntarily shared data from participating platform members, which makes it a conservative floor rather than a full market census — the actual ICHRA market is widely believed to be larger than any members-only sample can capture.

We share these statistics for education and cite them to their source. They are not a guarantee of results for any individual employer. For figures specific to your business, request a free quote.