IRA Policy Tracker: March 2026
This tracker summarizes the most consequential IRA tax credit policy developments as of March 2026: new Treasury guidance, regulatory finalization, pending proposed rules, and what each change means for active project development and credit monetization.
Correction, September 10, 2026: the original version of this tracker described an IRA rollback as a pending legislative risk. It had already happened. The One Big Beautiful Bill Act (P.L. 119-21) was signed July 4, 2025. The section below sets out what it changed.
Already Law: The One Big Beautiful Bill Act
The One Big Beautiful Bill Act ended or narrowed several of the credits this tracker follows:
- Section 45L new energy efficient home credit: terminated for homes acquired after June 30, 2026.
- Section 179D commercial building deduction: terminated for property whose construction begins after June 30, 2026. Projects that began construction on or before that date can still claim it in the year they are placed in service.
- Section 30C EV charging property credit: terminated for property placed in service after June 30, 2026.
- Section 25C and Section 25D residential credits: terminated after December 31, 2025.
- Section 30D, Section 25E and Section 45W clean vehicle credits: terminated for vehicles acquired after September 30, 2025.
- Section 48E and Section 45Y for wind and solar: projects must have begun construction by July 4, 2026, or be placed in service by December 31, 2027. Energy storage and other technologies keep the longer phase-down schedule. Foreign-entity-of-concern restrictions now apply.
- Legacy Section 48 and Section 45: cover only projects that began construction before 2025. Newer projects use Section 48E and Section 45Y.
- Section 45V clean hydrogen: only facilities that begin construction before January 1, 2028 qualify.
- State, New York City and utility programs are not affected.
Sources: IRS Fact Sheet FS-2025-05 (Sections 25C, 25D, 25E, 30C, 30D, 45L, 45W and 179D) and IRS Notice 2025-42 (beginning of construction for wind and solar).
What Changed in Early 2026
Section 45V Final Rules — Hydrogen Additionality
Treasury finalized the Section 45V clean hydrogen rules in early 2025, including the controversial hourly electricity matching requirement for electrolytic hydrogen. The final rule largely retained the proposed additionality, deliverability, and temporal matching framework from the 2023 proposed rules.
Impact: Under the final rules, projects using grid electricity can match clean energy certificates annually for electricity generated before 2030 and must match hourly after that (26 CFR §1.45V-4). Hourly matching significantly increases the cost of compliance but preserves the integrity of the lifecycle emissions standard. Separately, the One Big Beautiful Bill Act limits Section 45V to facilities that begin construction before January 1, 2028.
Domestic Content Safe Harbor Expansion
IRS Notice 2024-41 expanded the list of manufactured products eligible for the domestic content safe harbor, making it easier for solar and storage developers to document the 10% domestic content bonus adder without complex supply chain audits.
Impact: More projects can now claim the domestic content bonus with greater confidence. Manufacturers have updated their certification programs. The safe harbor covers modules, inverters, racking, and battery systems from compliant manufacturers.
Energy Community Map — Annual Update
The IRS publishes an annual update to the energy community designations. An update can add areas near recent power plant closures and metropolitan statistical areas with high fossil fuel employment concentrations.
Impact: Projects in newly designated energy communities can claim the 10-point ITC energy community adder if they have not yet begun construction, and wind and solar projects must also meet the One Big Beautiful Bill Act deadlines. Developers with pending pipeline should re-check project addresses against the current map.
Transferability Market Matures
The transferable tax credit market completed its second full year in 2025. Transfer under Section 6418 remains available for the credits the One Big Beautiful Bill Act left in place. It was never available for Section 45L or Section 179D.
Impact: The market is deeper and more liquid than it was at launch. More buyers (including insurance companies, family offices, and corporate treasury desks) have entered the market, reducing counterparty concentration risk and supporting pricing.
What Is Pending: Rules in Progress
Several important rules remain in proposed or interim final status as of March 2026. Developers should monitor these carefully as they affect project economics.
| Rule | Status | Key Issue | Timeline |
|---|---|---|---|
| 45X Advanced Manufacturing Credit | Final (2024) | Component definitions, foreign entity of concern exclusions | Final |
| Section 48E Technology-Neutral ITC | Amended by OBBBA | Wind and solar construction deadlines, Notice 2025-42 beginning-of-construction rules, foreign-entity-of-concern restrictions | In effect |
| Low-Income Community Bonus (Category 2) | Allocation rounds ongoing | Annual application window, scoring criteria | Annual |
| Apprenticeship Requirements | Final | Ratios, good faith exception guidance | Final |
| 45Q Carbon Capture (Utilization credits) | Proposed (2023) | Lifecycle emissions for EOR, utilization pathways | TBD |
What to Watch in 2026
Wind and Solar Placed-in-Service Deadline
Wind and solar projects that had not begun construction by July 4, 2026 must be placed in service by December 31, 2027 to qualify for Section 48E or Section 45Y. Treasury Notice 2025-42 tightened the beginning-of-construction rules, so projects relying on an earlier start date should document it carefully.
Foreign Entity of Concern (FEOC) Restrictions
Foreign-entity-of-concern restrictions now apply to the Section 48E and Section 45Y credits under the One Big Beautiful Bill Act. Developers sourcing equipment from manufacturers that could be foreign entities of concern should confirm eligibility with counsel before committing to a supply chain.
IRS Audits of Transferable Credits — Recapture Risk
The IRS has begun examining early transferable credit transactions. Common audit triggers include misclassification of eligible basis, domestic content bonus claims without adequate documentation, and energy community designations on incorrect census tracts. Proper documentation at project commencement is critical.
45V Hydrogen: Construction Deadline
The One Big Beautiful Bill Act limits Section 45V to facilities that begin construction before January 1, 2028. Developers should plan construction starts around that date and model project economics under the hourly matching requirement in the final rules.
Impact on Active Projects: Action Items for Developers
- ✓For wind and solar projects that had not begun construction by July 4, 2026: confirm they can be placed in service by December 31, 2027
- ✓For Section 179D claims: confirm and document that construction began on or before June 30, 2026
- ✓Re-run energy community classification on all pipeline projects using the current IRS designations
- ✓Verify domestic content bonus eligibility with manufacturers using the expanded safe harbor list
- ✓For hydrogen projects: confirm construction can begin before January 1, 2028, and model the hourly matching requirement in the final rules
- ✓Ensure transferable credit transactions from 2023–2024 are fully documented and bonus adder certifications are on file
- ✓Review 45Q projects for utilization pathway compliance pending proposed rules finalization
- ✓Review supply chains against the foreign-entity-of-concern restrictions that now apply to Section 48E and Section 45Y
Frequently Asked Questions
Did the One Big Beautiful Bill Act claw back credits already earned?
Its terminations take effect on dates after the law was signed on July 4, 2025, keyed to when a home is acquired, when construction begins, when property is placed in service, or when a vehicle is acquired. Credits tied to earlier dates are not affected by the terminations themselves.
How often does the IRS update the energy community map?
The IRS publishes updated energy community designations each year. Check the current IRS list rather than an old lookup, and check the map at project commencement to lock in the designation.
Does Treasury's 45V final rule require hourly matching for all hydrogen projects?
The final rules phase in hourly matching for electrolytic hydrogen that relies on grid electricity, with annual matching allowed during a transition period. Check the transition dates in the final Section 45V regulations. Separately, the One Big Beautiful Bill Act limits Section 45V to facilities that begin construction before January 1, 2028.
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