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. If you do not file a tax return and reconcile the premium tax credits for two consecutive years, you will not be eligible for premium tax credits in the future. Note, however, that this rule has been suspended until the IRS builds the systems necessary to enforce the requirement. Therefore, you won’t be denied premium tax credits if you failed to file taxes and reconcile your premium tax credits for coverage you had in 2022 or a prior year.
(CMS, Guidance on Annual Redetermination and Re-enrollment for Marketplace Coverage for 2024 and Later Years; 26 C.F.R. §§ 1.36B-2, 1.36B-4; IRS, Questions and Answers on the Premium Tax Credit.)