By David M. Newman, P.E., C.E.M., Vice President of Engineering, Energia

Time is Almost Up for Solar PV Projects
Get your solar installations underway before the end of 2025 to avoid complications related to foreign material content.

The passage of the “One Big Beautiful Bill Act” (OBBBA) has introduced new urgency for municipalities considering solar photovoltaic (PV) projects. While previous federal incentives under the Inflation Reduction Act (IRA) created a strong financial case, OBBBA has established critical deadlines that must be addressed to ensure current projects remain viable and eligible for the Investment Tax Credit (ITC).

The key provisions of OBBBA that directly impact solar PV projects are:

  • Foreign Entity Rules: All projects must comply with Foreign Entity of Concern (FEOC) rules for construction beginning after December 31, 2025.
  • Repeal of ITC: The ITC is repealed for all projects placed in service after December 31, 2027. However, projects that begin construction before July 4, 2026, can still be placed in service after this date.
  • Definition of “Construction”: “Construction” is a crucial term here. It is defined by the IRS as incurring at least 5% of the total project cost in physical installation activities, materials, and equipment.
Beyond the financial and logistical impacts of OBBBA, this is a moment to assess the underlying vulnerabilities

In short, the ideal situation is to get solar installations underway before the end of this year (2025) to avoid potential complications related to foreign material content. We anticipate that existing equipment will remain compliant, but if the IRS were to tighten these rules, it could significantly impact supply chains and project timelines.

For larger systems, the construction deadline of December 31, 2027, presents a clear challenge, making it essential to start construction before July 4, 2026.

Does Your Municipality Desire Solar PV, Particularly a Large Installation?

If your municipality desires solar PV, particularly large installations like carports and ground mounts, there is a strong argument to push the project forward as soon as possible. Acting quickly will allow you to stay ahead of these dates and ensure your project’s financial and logistical success.

For a broader overview of the new energy landscape and how to navigate it, please read my full article, “Energy Incentives Post-OBBBA: Risks, Realities, and a Resilient Path Forward for Municipalities.