No, not necessarily.
According to Who Can Take the PTC in the Instructions for Form 8962,
having household income below 100% of the federal poverty line will not disqualify you from taking the PTC if you meet certain requirements.
Per the instructions,
You may qualify for the PTC if your household income is less than 100% of the federal poverty line and you meet all of the following requirements.
• You or an individual in your tax family enrolled in a qualified health plan through a Marketplace.
• The Marketplace estimated at the time of enrollment that your household income would be at least 100% but not more than 400% of the federal poverty line for your family size for 2020.
• APTC was paid for the coverage for one or more months during 2020.
• You otherwise qualify as an applicable taxpayer (except for the federal poverty line percentage).
You do not meet the requirements under Estimated household income at least 100% of the federal poverty line if:
• No APTC was paid for your or your family's coverage; or
• You, with intentional or reckless disregard for the facts, provided incorrect information to a Marketplace for the year of coverage.
