If this is your first time applying for the premium tax credit, then yes. There is no requirement to have filed a tax return for any prior year in order to qualify for a premium tax credit for the first time. However, under regular rules, there is a requirement to file a tax return in the year in which you receive a premium tax credit and to reconcile the advance payments of premium tax credits using IRS Form 8962. Otherwise, you will not be eligible for premium tax credit in the future.
Note, however, that this rule does not apply for plan years 2021 or 2022. Under guidance granting flexibility to taxpayers in response to COVID-19, you won’t be denied premium tax credits because you failed to file taxes and reconcile your premium tax credits for coverage you had in 2020 or if there was a delay in the IRS processing of your tax return. However, you will still need to attest to having filed and reconciled when you update your application for 2022 coverage. (26 C.F.R. § 1.36B-2; IRS, Questions and Answers on the Premium Tax Credit; CMS, Failure to File and Reconcile (FTR) Operations Flexibilities for Plan Years 2021 and 2022 – Frequently Asked Questions (FAQ)).