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Clean Electricity Investment Credit (Section 48E)
IRS / U.S. TreasurySee programDeadline: Wind/solar: BOC by July 4, 2026 (5% safe harbor available for ≤1.5 MWac) OR PIS by Dec 31, 2027. Standalone storage and other clean tech (geothermal, nuclear, hydro): preserved through BOC 12/31/2033. FEOC restrictions apply for BOC on or after 6/16/2025.
Federal investment tax credit under IRC Section 48E (technology-neutral successor to legacy Section 48 ITC). Established by IRA for facilities placed in service after 12/31/2024. Modified by OBBBA (P.L. 119-21, July 4, 2025) — wind and solar face a BINARY CLIFF, not a gradual phase-down: 30% preserved if BOC on or before July 4, 2026 (with 4-year continuity safe harbor allowing PIS as late as Dec 31, 2030 for 2026 starts) OR PIS by Dec 31, 2027 if BOC after July 4, 2026. IRS Notice 2025-42 (effective 9/2/2025) narrowed the 5% Safe Harbor BOC method to solar facilities ≤1.5 MWac only; wind and solar >1.5 MWac must use the Physical Work Test. Standalone battery storage and other non-solar/wind clean tech retain the full IRA schedule (full 30% through BOC 12/31/2033, with phase-down 75%/50%/0% in 2034/2035/2036) and BOTH BOC methods. New FEOC ownership/material restrictions effective for BOC on or after June 16, 2025. Most evlv.energy solar projects fall under 48E (not 45Y) since clients want one-time ITC vs decade of PTC. For typical EVLV client (small/medium IL commercial rooftop, under 1.5 MWac), the 5% Safe Harbor is the actionable path.
Program details
- Agency
- IRS / U.S. Treasury
- Level
- Federal
- Category
- Solar / Clean Electricity / Storage
- Eligibility
- Owners of qualified clean electricity facilities placed in service after 12/31/2024, including solar PV, wind, storage (≥3 kWh), geothermal, nuclear, hydro, marine/hydrokinetic. Direct pay available for tax-exempt entities (non-profits, government, tribal); transferability to third parties allowed under IRC Section 6418. BOC test per IRS Notice 2025-42 (effective 9/2/2025): (a) Physical Work Test — any size, (b) 5% Safe Harbor — solar facilities ≤1.5 MWac ONLY (storage retains both methods).
- Funding Amount
- 30% base ITC, up to 70% with bonus adders (energy community +10%, domestic content +10%, low-income community +10–20%). For wind/solar: 30% preserved IF Begin Construction (BOC) on or before July 4, 2026 (4-year continuity safe harbor: PIS by Dec 31, 2030 for 2026 starts) OR PIS by Dec 31, 2027 if BOC after that date. For standalone storage / other clean tech: 30% through BOC 12/31/2033, then 75% (2034), 50% (2035), 0% (2036+).
- Deadline
- Wind/solar: BOC by July 4, 2026 (5% safe harbor available for ≤1.5 MWac) OR PIS by Dec 31, 2027. Standalone storage and other clean tech (geothermal, nuclear, hydro): preserved through BOC 12/31/2033. FEOC restrictions apply for BOC on or after 6/16/2025.
- Status
- closing_soon
- Project Types
- solar, storage, clean_electricity
- Client Types
- commercial, utility, nonprofit
- Notes
- For evlv.energy solar calculator: 30% ITC default REMAINS CORRECT for systems with BOC on or before July 4, 2026. Pitch: "Spend 5% by July 4, 5 years to install" — for systems ≤1.5 MWac, locking in 5% of project cost (panels, inverters, batteries) by July 4, 2026 satisfies BOC and grants the 4-year continuity safe harbor (PIS as late as Dec 31, 2030 for 2026 starts). Systems >1.5 MWac need Physical Work Test. Standalone storage is fully insulated from the wind/solar cliff (through 2033 BOC). Diligence required: (a) FEOC compliance on inverter/panel/battery sourcing for 2026+ BOC; (b) energy-community bonus check (most of IL outside Chicago = energy community = +10%); (c) prevailing-wage + apprenticeship gate for systems >1 MW (otherwise 6% base). Stack with: USDA REAP, DOE Loan Programs Office, state utility programs (IL Shines, IL DG Storage Rebate).
Source: Grantya research. Confirm current terms with the administering agency before applying.