Is ICHRA Growing? 2025 Adoption Trends
July 9, 2026 · 5 min read
Short answer: yes — dramatically. ICHRA has gone from a brand-new rule in 2020 to one of the fastest-growing benefits in the country, and the most recent data shows the momentum accelerating across every employer size.
The headline: over 1,000% growth
Since 2020, ICHRA adoption has grown by more than 1,000% (HRA Council, 2024–2025). That''s the kind of curve you rarely see in employee benefits, and it reflects both first-time adopters and employers switching from other models.
Small-business adoption keeps climbing
Small employers remain the heart of ICHRA. Small-business ICHRA adoption rose 52% year over year among the longest-tenured providers, and the majority of all adopters have 20 or fewer employees — many offering health benefits for the very first time.
Large employers are surging
The fastest growth is now among Applicable Large Employers (50+ employees), up 34% year over year, with mid-market cohorts (100–199 employees) growing nearly 50%. ICHRA has clearly outgrown its small-business origins.
QSEHRA is growing too
It''s not just ICHRA. QSEHRA — the capped version for employers under 50 — has doubled in adoption since 2020, showing that defined-contribution health benefits as a whole are gaining ground.
Strong retention, not churn
Growth isn''t coming at the expense of stickiness. More than 90% of employers offering an ICHRA or QSEHRA renew it year to year — evidence that adopters are satisfied and staying, not experimenting and leaving.
Why it''s growing
The drivers are consistent: predictable costs employers control, tax-free dollars, no participation minimums, and employee choice. Add bipartisan policy support and a maturing ecosystem of platforms and brokers, and the growth makes sense.
What it means for you
Rapid growth plus high retention signals a maturing, proven benefit rather than a risky experiment. If you''ve been waiting to see whether ICHRA would stick, the data suggests it has — and it may be worth a closer look for your business.
Frequently asked questions
Very fast — adoption is up more than 1,000% since 2020, with small-employer adoption rising 52% and large-employer adoption 34% in the most recent year (HRA Council, 2024–2025).
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