Key Takeaways
- Devenir's midyear research found health savings accounts held about $192 billion across 42.6 million accounts at June 30, 2026, with assets up 20% in a year against 7% account growth.
- Invested balances reached $100 billion, or 52% of all HSA assets, up from 46% a year earlier, the first time investments have made up the majority.
- In the first half of 2026 account holders contributed $35.2 billion and withdrew $23.8 billion, and accounts opened in 2026 put in more than $4 for every $1 taken out.
- CMS reports 43% of HealthCare.gov plan selections for 2026 were HSA-eligible, up from 2% a year earlier, after all bronze and catastrophic plans became eligible.
For health and wellness brands, "HSA eligible" has usually been a line in the product description, a small badge near the price that tells a shopper they can pay with pre-tax money. The newest data on the accounts themselves suggests that badge is doing less work than it used to. Balances are growing quickly, but a rising share of the money is being invested for the long term rather than kept on hand for the next purchase. At the same time, a change in federal rules has pushed millions of new people into HSA-eligible coverage, many of whom have never had an account before. Together those shifts change what product marketers need to say, and to whom, heading into open enrollment season.
The Balance Is Growing Faster Than the Spending
The headline figure comes from Devenir's 2026 midyear research, reported by the ABA Banking Journal on October 13. HSAs held about $192 billion across 42.6 million accounts as of June 30, 2026. Assets rose 20% year over year while the number of accounts grew 7%, so the growth is coming mostly from bigger balances rather than new holders. Invested balances reached $100 billion, or 52% of all HSA assets, up from 46% a year earlier. Some 4.4 million accounts now hold at least $10,000, six times the level a decade ago, and nearly 1.9 million hold $25,000 or more.
The cash flows explain the shift. In the first six months of 2026, holders contributed $35.2 billion and withdrew $23.8 billion, retaining $11.5 billion. Newer accounts are saving hardest: those opened in 2026 contributed more than $4 for every $1 withdrawn. Devenir's 2025 year-end report shows the same pattern building over time, with contribution-to-withdrawal ratios of 1.3x for accounts opened in 2023, 1.8x for 2024 and 2.8x for 2025. Across the whole of 2025, contributions were nearly $60 billion and withdrawals nearly $45 billion.
That withdrawal figure is the number a product marketer should care about. It is the money actually leaving accounts to pay for care, prescriptions, eyewear and the long tail of eligible products, and it is still a very large pool. But it is now the smaller half of the story. A growing number of account holders treat their HSA as a second retirement account, which means an eligible product is competing not only with other brands but with the holder's own decision to leave the money invested.
Of HSA assets were invested rather than held as cash at mid-2026, the first time investments have been the majority.
A New Wave of Account Holders Is Arriving Through the Marketplace
While established holders are saving more, the audience is also changing shape. Under the One Big Beautiful Bill Act, every bronze and catastrophic plan sold on the ACA Exchanges became HSA-eligible from January 1, 2026. The effect was immediate. The CMS report on 2026 open enrollment found that 43% of consumers with plan selections through HealthCare.gov enrolled in HSA-eligible plans, against 2% during the 2025 enrollment period. With 15.8 million plan selections on the HealthCare.gov platform, that is roughly 6.8 million selections in eligible coverage, out of 23.1 million Exchange selections nationwide.
These are not the typical HSA holders of the past, who mostly opened accounts through an employer's high-deductible plan and often had a benefits team explaining how they worked. Marketplace enrollees choosing bronze coverage are frequently cost-driven buyers who may not know they can open an account at all, let alone which purchases qualify. For them, "HSA eligible" is not a reassurance; it is an unfamiliar term that needs explaining. Devenir's year-end report projects the market will pass 49 million accounts and $234 billion in assets by the end of 2028, and a meaningful part of that growth will come from people learning the rules for the first time.
Of HealthCare.gov plan selections for 2026 were HSA-eligible, up from 2% the year before, according to CMS.
What Counts as Eligible Just Widened
The same law also changed what the money can be spent on. IRS guidance issued in December 2025, summarised by PlanAdviser, confirmed that people in HSA-eligible plans can now take part in direct primary care arrangements and pay the periodic fees from their HSA tax-free, provided the fees are $150 a month or less for individual coverage and $300 or less for family coverage. It also made permanent the safe harbor that lets holders use telehealth and other remote care before meeting their deductible without losing eligibility to contribute.
For subscription primary care and virtual care brands, that turns a payment method into a positioning claim. A membership priced under the $150 threshold can now be described, accurately, as payable from an HSA, and a telehealth service can tell a bronze-plan member that using it does not jeopardise their account. Those are concrete, checkable statements, which is exactly what a new or cautious account holder needs before deciding to draw down money they might otherwise invest.
- Market eligibility as a benefit, not a badge. Explain in plain language that the purchase can be paid with pre-tax HSA dollars and what that saves, because many new holders have never been told how.
- Plan for open enrollment as a launch window. The months when people choose plans and set contributions are when HSA messaging is most relevant, for employer and Marketplace audiences alike.
- Price memberships with the thresholds in mind. Direct primary care fees at or under $150 a month for individuals, or $300 for families, can be paid from an HSA; above that, the claim no longer holds.
- Make checkout accept the card. Withdrawals still ran to $23.8 billion in six months, and a buyer who has to pay out of pocket and claim later is a buyer who may simply leave the money invested.
- Segment new holders from savers. A first-year bronze enrollee needs education about eligibility, while a holder with a five-figure invested balance needs a reason the purchase is worth it.
- Measure without leaking health data. HSA-driven campaigns often touch prescriptions and care, so attribution has to stay inside what privacy rules allow ad platforms to receive.
The HSA market is bigger than it has ever been, but it is not simply a larger wallet waiting at checkout. More of the money is being saved, and more of the holders are new to the rules. Brands that treat eligibility as something to explain and make easy to use, rather than a badge to display, will be the ones that convert the growth into revenue.
