Zero-emission electricity projects such as wind, solar, battery storage, and geothermal projects that begin construction and are placed in service in 2025 may be subjected to payment recapture rules, pending guidance.
Zero-emission electricity projects that commence construction in 2025 but plan to claim the credit in 2026 must comply with new prohibited foreign entity (PFE) restrictions except those regarding material assistance.
Zero-emission electricity projects such as wind, solar, battery storage, and geothermal projects, that commence construction in 2026 must comply with all new supply chain PFE restrictions.
Note: An executive order directs the Treasury Department to issue guidance by August 18, 2025, on “commence construction” definitions for wind and solar projects that is expected to further curtail solar and wind projects.