2025 Midyear Devenir HSA Research Report

Key Findings

Market momentum amplifies asset growth

Supported by favorable markets, HSA assets expanded meaningfully in the first half of 2025. By midyear, assets reached nearly $159 billion across about 40 million accounts, up 16% year-over-year for assets and 6% for accounts.

Investment assets climb to record levels

Investment balances benefited from strong market returns and growing recognition of HSAs’ long-term advantages. At midyear 2025, investment assets rose to nearly $73 billion, a 30% year-over-year increase.

Steady expansion in investing

About 4 million HSAs, roughly 10% of all accounts, held at least some of their HSA dollars in investments. The number of investing accounts was up 23% year-over-year.

Withdrawals grew faster than contributions

In the first half of 2025, contributions totaled over $33 billion (up 6% year-over-year) and withdrawals totaled almost $23 billion (up 11% year-over-year).

Source: Devenir Research

HSA Industry Level Account Data

The pace of account growth has continued to moderate toward a rate of about 5% year-over-year, though this is expected to accelerate following passage of the One Big Beautiful Bill Act. There continues to be some seasonality in the percentage of accounts that are unfunded. Accounts are often opened during the fall open enrollment season, but remain unfunded until early the following year. At the midyear point of 2025, about 19% of all accounts were unfunded, unchanged from the previous year.

Source: Devenir Research

A clear correlation is seen between account age and balance size. Funded accounts opened in 2004 have the highest average balance at $33,010, while those opened in the first half of 2025 average $1,723. This pattern holds consistently across the years, with a gradual decline in average balances for more recently opened accounts. The data demonstrates the cumulative effect of long-term HSA ownership, with older accounts benefiting from extended periods of potential contributions and possible investment growth.

Source: Devenir Research

Industry Contributions & Withdrawals

Source: Devenir Research

Industry Estimate of HSA Contributions and Withdrawal Activity for the period 1/1/2025 - 6/30/2025.

First Half 2025 Activity	Contributions	Withdrawals	Retained Assets
Estimated Industry Totals	$33,032,000,000	$22,724,000,000	$10,308,000,000

Industry Contributions

The dominance of contributions made through employer channels (either by the employer or employee) in the first half of 2025 underscores the integral role of company-backed health benefits, while a smaller yet significant individual contribution segment suggests a growing awareness and personal responsibility in health savings.

Source: Devenir Research

Industry Withdrawals

Source: Devenir Research

Debit card transactions continued to be the dominant way account holders access their HSA funds in the first half of 2025.

Source: Devenir Research

First Half 2025 Withdrawal Methods Breakdown

Method	Average Number of Withdrawals Per Account	% Of Total Withdrawals (#)	Average Transaction Size
Debit Card	4.3	91%	$123
Check	<0.1	1%	$602
Online Bill Pay	0.3	6%	$201
ATM	0.1	<1%	$135
Unknown	0.2	2%	$473

Debit Card

Average Number of Withdrawals Per Account4.3

% Of Total Withdrawals (#)91%

Average Transaction Size$123

Check

Average Number of Withdrawals Per Account<0.1

% Of Total Withdrawals (#)1%

Average Transaction Size$602

Online Bill Pay

Average Number of Withdrawals Per Account0.3

% Of Total Withdrawals (#)6%

Average Transaction Size$201

ATM

Average Number of Withdrawals Per Account0.1

% Of Total Withdrawals (#)<1%

Average Transaction Size$135

Unknown

Average Number of Withdrawals Per Account0.2

% Of Total Withdrawals (#)2%

Average Transaction Size$473

Note: Due to rounding, the above table may not total 100%.

HSA Investments

$72.9 billion estimated in HSA investment assets as of June 30th, 2025, which is an increase of 30% year-over-year.
46% of all HSA assets are in investments as of June 30^th, 2025.
$22,635 average total balance (deposits and investments combined) for HSA investment accounts, 8 times larger than an average funded non-investment holder's account balance.

Source: Devenir Research

Looking Forward

HSA providers project HSA industry asset growth of 13% in 2025 (down from 15% at the end of 2024), while anticipating their own business will grow by 21% during the same period (unchanged from the end of 2024). As a greater share of HSA assets are held in investments, market movement will make forward looking asset projections more difficult.

We now ask providers to forecast industry account growth as well. At the midyear point of 2025, HSA providers anticipated we will see industry HSA account growth of 5% for 2025 (down from 6% at the end of 2024).

Devenir projects that the HSA market will surpass 47 million accounts and hold over $208 billion in assets by the end of 2027.

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Report Methodology

The majority of this report was derived from the 2025 Midyear Devenir HSA Market Survey. The survey was carried out in the summer of 2025 and all data was requested for the period ending on June 30^th, 2025.

All estimates and projections reflect the current environment surrounding health savings accounts and do not contemplate any future regulatory changes to the market. Certain data points from the survey were omitted from this report due to inconclusive data or an incomplete sample set. All statistics are produced using the best available data set, which may at times produce statistics which do not reconcile, either with other statistics in this report or with previous reports.

Survey responses are self-reported by each HSA provider. When possible Devenir attempts to verify responses through a variety of channels, including but not limited to, press releases, annual reports, prior research, and FDIC filings.

About Devenir

Devenir is a national leader in providing customized investment solutions for HSAs and the consumer directed health care market. When health savings accounts first emerged in 2004, Devenir built its expertise around delivering cutting-edge investment solutions. As the consumer driven health care industry grew, so did Devenir's reputation as a leading researcher and award-winning investment consultant. Today, Devenir continues to lead the way in the rapidly growing HSA market. A research driven perspective makes Devenir the go-to investment advisor, HSA investment platform and consultant to employers, banks, third party administrators, health plans, and technology providers. Learn more at devenir.com.

Devenir Research Team

Jon Robb — Senior Vice President, Research & Technology
Eric Remjeske — President, Founder
Garrick Fults — Investment Analyst

© Devenir Group, LLC (Devenir). All Rights Reserved. Reproduction or redistribution of this report by any means is strictly prohibited. The information, data, analyses, and opinions presented herein do not constitute business or investment advice; are provided solely for informational purposes; and is not warranted to be correct, complete, or accurate. The opinions are expressed as of the date written and are subject to change without notice. Except as otherwise required by law, Devenir, shall not be responsible for any decisions, damages, or other losses resulting from, or related to, the information, data, analyses, or opinions or their use. The information contained herein is the proprietary property of Devenir and may not be reproduced or redistributed, in whole or in part, or used in any manner, without the prior written consent of Devenir.

For further information, please contact Devenir Research at 952-446-7400 or [email protected]