If you've been tracking IRA energy credits for your commercial properties, July 4, 2025 changed the landscape significantly. President Trump signed the One Big Beautiful Bill Act (OBBBA) into law, a sweeping reconciliation package that accelerated the sunset of several Inflation Reduction Act clean energy provisions while leaving others — with tightened deadlines — still on the table.

The problem is that the information circulating online is either outdated (reflecting pre-OBBBA IRA guidance), incomplete, or conflates commercial and residential provisions. This guide focuses exclusively on commercial building owners, developers, and businesses, drawing on primary sources to tell you exactly where things stand as of Q1 2026.

Time-Sensitive

The most important surviving commercial credits — Section 48E (Investment Tax Credit) and Section 45Y (Production Tax Credit) — require construction to begin by July 4, 2026. That is fewer than 100 days from today. Projects that miss this window lose access entirely.

<\!-- SECTION 1 -->

1. The OBBBA Changed the Rules — Here's What Happened

The One Big Beautiful Bill Act was designed primarily as a tax and spending reconciliation bill, and it achieved its energy policy objective by rolling back much of the IRA's clean energy investment framework. The law did not eliminate every IRA credit immediately — it was more surgical than that — but it created hard termination dates that caught many property owners and developers off guard.

The core mechanism: OBBBA moved termination dates for many credits to before the originally scheduled 2032–2035 expiration written in the IRA. For some credits like Section 45W (commercial clean vehicles), the termination was retroactive to September 30, 2025 — leaving businesses with projects in progress holding an unpleasant surprise.

For commercial real estate specifically, the two most consequential changes were:

  • Section 179D (Energy-Efficient Commercial Building Deduction): No longer available for construction beginning after June 30, 2026. Projects in design or early planning must begin construction before that date to preserve eligibility.
  • Section 48E / 45Y (Clean Electricity Credits): These survive but are now gated behind a construction-commencement deadline of July 4, 2026, with a placed-in-service deadline of December 31, 2027 for full credit value.

The law also outright repealed several residential credits — most notably Section 25D (residential solar and energy storage credits) — which don't directly affect commercial properties but are relevant to mixed-use buildings and multifamily owners with residential units.

<\!-- SECTION 2 -->

2. What's Gone: Credits That Expired or Were Terminated

The following credits are no longer available for new commercial projects based on the OBBBA termination dates. If you were planning around these, you need to reconfigure your project economics immediately.

IRC Section Credit Name Original IRA Expiry OBBBA Termination Status
§ 30D Clean Vehicle Credit (new) 2032 Sep 30, 2025 Expired
§ 25E Previously Owned Clean Vehicle Credit 2032 Sep 30, 2025 Expired
§ 45W Commercial Clean Vehicles Credit 2032 Sep 30, 2025 Expired
§ 30C Alt. Fuel Vehicle Refueling Property (EV Chargers) 2032 Jun 30, 2026 (PIS) Deadline Passed*
§ 179D Energy-Efficient Commercial Building Deduction Permanent Construction begins after Jun 30, 2026 Act Now
§ 25D Residential Clean Energy Credit (solar) 2034 Repealed Repealed

*Section 30C: Property placed in service after June 30, 2026 is not eligible. EV charging infrastructure placed in service on or before that date still qualifies under the original IRA terms.

A Note on Section 179D

Section 179D deserves special attention for commercial building owners because it was one of the most widely used commercial energy incentives. The deduction — up to $5.65 per square foot for highly efficient buildings — is still available for projects where construction began on or before June 30, 2026. This is a construction-start test, not a placed-in-service test, so buildings in active construction before that date can still qualify even if they complete well into 2027 or later. For a detailed breakdown of what still qualifies, see our Section 179D guide for 2026.

<\!-- SECTION 3 -->

3. What's Still Standing: Available Commercial Credits

Despite the terminations, significant commercial energy incentives remain available — and for projects that move quickly, the economics are still compelling. Here is the current landscape:

IRC Section Credit / Incentive Base Rate Key Deadline Notes
§ 48E Clean Electricity Investment Tax Credit (ITC) 6–30% Begin construction by Jul 4, 2026 Available
§ 45Y Clean Electricity Production Tax Credit (PTC) 0.3¢–3¢/kWh Begin construction by Jul 4, 2026 Available
§ 45Q Carbon Capture & Sequestration Credit $60–$85/ton No new deadline set Survived
§ 45X Advanced Manufacturing Production Credit Varies by component Wind components phased out* Largely Available
MACRS Accelerated Depreciation (5-year schedule) Bonus depreciation Standard IRS schedule Available
REAP Rural Energy for America Program Grant Up to 50% cost USDA cycle funding Available
§ 6418 Credit Transferability — Retained Retained

*Section 45X: The wind turbine component credits (blades, nacelles, towers) are being phased out; solar components, battery storage components, and critical minerals manufacturing credits remain active.

Section 48E: The ITC That Still Works for Commercial Solar

The Section 48E Clean Electricity Investment Tax Credit is the principal vehicle for commercial solar, battery storage, and other clean electricity investments after OBBBA. It replaced the legacy Section 48 ITC and offers a base credit of 6% of qualifying property cost, with pathways to reach 30% or higher through bonus adders:

  • Prevailing Wage + Apprenticeship requirements met: Base rate increases from 6% to 30%
  • Domestic Content Bonus: Additional 10% ITC (or 10 percentage points added to the base)
  • Energy Community Bonus: Additional 10% for projects in qualifying fossil fuel transition communities
  • Low-Income Community Bonus: Additional 10–20% for eligible census tracts

The construction-commencement deadline is July 4, 2026. Projects must also be placed in service by December 31, 2027 to receive the full credit value; projects placed in service in 2028 receive a reduced credit, and 2029 placements receive further reductions.

Section 45Q: Carbon Capture's Survival

Section 45Q — the carbon capture and sequestration credit — survived OBBBA largely intact, and the credit values were actually increased under the bill. Industrial facilities and power plants capturing CO₂ for sequestration or utilization now benefit from $60/metric ton for geological sequestration and $85/ton in some enhanced scenarios. If your commercial portfolio includes manufacturing, industrial, or power generation assets, this credit merits serious analysis.

<\!-- NEWSLETTER INLINE CTA — at approximately 60% through article --> <\!-- SECTION 4 -->

4. The Critical Deadlines for 2026

The timeline below maps the most important dates for commercial building owners and project developers. Missing any of these means losing access to credits that may represent millions of dollars in project economics.

September 30, 2025

EV Credits Terminated

Sections 30D, 25E, and 45W (commercial clean vehicles) all expired. No new applications accepted after this date.

June 30, 2026

Last Day for Section 30C (EV Chargers) & Section 179D Construction Start

EV charging infrastructure must be placed in service on or before this date. Section 179D construction must begin on or before this date. Both deadlines are firm.

July 4, 2026

Construction Must Begin: Sec. 48E & Sec. 45Y

This is the critical start-of-construction deadline for the Clean Electricity ITC and PTC. Projects that fail to meet this date lose access to these credits entirely. IRS Notice guidance on "begin construction" tests (physical work + 5% safe harbor) applies.

December 31, 2027

Full Credit — Placed-in-Service Deadline (48E / 45Y)

Projects that commenced construction by July 4, 2026 must be placed in service by this date to receive the full credit rate. Projects placed in service in 2028 receive a partial credit; 2029 and beyond receive further reductions per the phase-down schedule.

What "Begin Construction" Means for Section 48E / 45Y

Under IRS Notice 2021-41 (and predecessor guidance), you can establish construction commencement two ways: (1) the Physical Work Test — beginning significant physical work of a permanent nature on the qualifying facility — or (2) the 5% Safe Harbor — paying or incurring at least 5% of the total project cost before the deadline. Both tests carry a continuous construction requirement. Consult your tax advisor now if you intend to use the safe harbor.

<\!-- SECTION 5 -->

5. How to Stack Multiple Credits

The most financially sophisticated commercial building owners are not relying on a single credit — they are stacking multiple incentives that apply to the same project. The good news is that most surviving credits can be combined without triggering reduction rules. Here is how a well-structured commercial solar + storage project can layer incentives:

Example: 500 kW Commercial Solar + 250 kWh Battery Storage, Rural Location

§ 48E ITC (base + PWA)
30% Federal ITC
30%
Domestic Content Bonus
+10%
+10%
MACRS Depreciation (yr 1)
~26% tax value*
~26%
REAP Grant (rural agri/small biz)
Up to 50% of cost
≤50%
Combined first-year economic benefit (all incentives applied, typical scenario) 60–80%+ of project cost

*MACRS percentage reflects approximate tax savings at a 21% corporate rate using 5-year MACRS schedule and 60% bonus depreciation (2026 rates). Actual results vary. REAP availability depends on USDA funding cycles and eligibility.

The key interactions to understand:

  • REAP + ITC: USDA REAP grants reduce your basis for ITC calculation. If you receive a $100,000 REAP grant on a $500,000 project, your ITC basis becomes $400,000. This is still advantageous, but you need to model it properly.
  • MACRS + ITC Basis Reduction: When you claim the ITC, your depreciable basis is reduced by 50% of the credit amount. So on a $1M project with a 30% ITC ($300,000 credit), your MACRS basis is $1M minus $150,000 = $850,000. This is well-established IRS treatment.
  • ITC Transferability (§ 6418): If your company does not have sufficient tax liability to use the full ITC in the year of placement, you can sell the credit to a third party through the transferability provisions retained under OBBBA. This dramatically improves economics for smaller commercial entities.

Use our IRA credit calculator to model these stacking scenarios for your specific project size, location, and tax situation.

<\!-- SECTION 6 -->

6. The New Domestic Content Requirements

The Domestic Content Bonus — an additional 10 percentage points on the Section 48E ITC — is one of the most valuable bonus adders available, but it carries specific compliance requirements that you must address at the procurement stage, not after installation.

Under the IRS Domestic Content Guidance (Notice 2023-29 and subsequent updates), qualifying solar projects must meet these "manufactured product" requirements:

  • Iron and steel components: All iron and steel used as construction materials must be produced in the United States
  • Manufactured products (adjusted percentage test): The domestic content percentage of manufactured products — including solar modules, inverters, racking, and battery cells — must meet threshold percentages that increase over time
  • 2026 threshold: Approximately 45% of manufactured product value must be U.S.-origin (verify current IRS guidance as thresholds have been updated)
  • Certification requirements: Manufacturers must provide documentation; project owners cannot self-certify based on country of origin labels alone
Practical Tip

Major U.S.-based solar module manufacturers including First Solar, Hanwha Q CELLS (Georgia facility), and several emerging domestic manufacturers now produce qualifying equipment. Ask your installer or EPC contractor specifically for modules with domestic content certification documentation before signing procurement contracts. This is easiest to negotiate pre-contract and extremely difficult to retrofit after installation.

Connecting with solar tax credit specialists in our marketplace can help you identify domestic content-compliant equipment and procurement channels that are pre-vetted for this bonus.

<\!-- SECTION 7 -->

7. Action Plan: What Commercial Building Owners Should Do Now

With fewer than 100 days until the July 4, 2026 construction-commencement deadline, here is the concrete sequence of actions for owners who want to capture the remaining IRA commercial credits:

  1. Audit your current portfolio for eligible properties (this week). Identify buildings where solar, battery storage, or other qualifying clean electricity investments make economic sense. Prioritize large flat-roof commercial properties, manufacturing facilities, warehouses, and rural locations with REAP eligibility. Start with a free energy audit to screen for the best opportunities.
  2. Model the credit stack for shortlisted properties (within 2 weeks). Use our IRA calculator to estimate ITC, domestic content bonus, MACRS, and REAP value for each site. Include the ITC basis reduction and REAP interaction in your model.
  3. Engage a qualified tax advisor now (not later). The "begin construction" safe harbor requires 5% of project costs paid or incurred before July 4, 2026. Your tax advisor needs time to structure this properly, especially if you are using the safe harbor rather than physical work evidence.
  4. Solicit installer bids with domestic content specifications (within 30 days). Request documentation confirming domestic content percentages for all manufactured products. This is a contractual requirement, not a checkbox. Connect with vetted commercial solar specialists who have domestic content experience.
  5. Evaluate credit transferability if your tax liability is limited. If your company's tax position means you cannot fully utilize a large ITC in year one, explore the transferability market. Several financial intermediaries now facilitate ITC transfers at favorable pricing.
  6. For rural agricultural or small business properties: apply for REAP now. USDA REAP grant applications are competitive and cycle-based. Earlier submissions in funding cycles have better outcomes. Factor the grant's basis-reduction effect into your ITC calculation.
  7. Do not wait on 179D-eligible buildings. If you have commercial buildings undergoing significant renovation or new construction, the Section 179D deduction construction-start deadline is June 30, 2026 — one week before the 48E deadline. Coordinate with your contractor and tax professional.
<\!-- SECTION 8 — FAQ -->

8. Frequently Asked Questions

A signed contract alone does not establish construction commencement. You need to either (1) begin significant physical work of a permanent nature on the facility before July 4, 2026, or (2) pay or incur at least 5% of the total project cost before that date (the 5% safe harbor). Consult your tax advisor about satisfying the safe harbor through equipment deposits or site preparation costs that qualify under IRS guidance.
Yes. Unlike the legacy Section 48 ITC which had co-location requirements, Section 48E explicitly includes standalone energy storage technology as a qualifying facility. Commercial battery storage systems with at least 5 kWh of capacity can qualify for the ITC without being co-located with solar generation. This is one of the most underutilized provisions remaining in the post-OBBBA landscape.
For projects that commenced construction by July 4, 2026 but are placed in service after December 31, 2027, the ITC rate phases down: 2028 placement receives a reduced credit, and further reductions apply for later years. The exact phase-down percentages should be confirmed with current IRS guidance, as implementation rules continue to be issued. In most cases it is still economically worthwhile — a reduced ITC is significantly better than no ITC — but your project proforma should model the actual reduced rate rather than the full rate.
REAP (the USDA Rural Energy for America Program) remained funded as of Q1 2026. The program covers up to 50% of eligible project costs for rural agricultural producers and rural small businesses installing renewable energy or energy efficiency improvements. Applications are accepted on a rolling basis with periodic funding cycles. Eligibility requires a rural location and either an agricultural producer or small business designation. Check USDA's REAP portal for current funding availability and open application windows.
Yes, through the Direct Pay (Elective Pay) mechanism established under IRA Section 6417 and retained post-OBBBA. Tax-exempt organizations, state and local governments, Tribal entities, and certain other entities that cannot use tax credits can elect to receive a direct payment from the IRS equal to the credit amount. This applies to Section 48E and a number of other qualifying credits. The election must be made on the organization's annual return, and specific compliance steps apply. Nonprofits with commercial real estate holdings should absolutely explore this pathway.
Prevailing Wage and Apprenticeship (PWA) requirements apply to all Section 48E projects with a maximum output capacity of 1 MW or greater. Projects under 1 MW are exempt and automatically qualify for the full 30% base rate. For larger projects, contractors must pay prevailing wages as determined by the Department of Labor and meet qualified apprenticeship requirements throughout construction and for the first five years of operation. Non-compliance results in penalties plus the ITC reverting to the 6% base rate — a significant financial consequence. Work with a contractor experienced in PWA compliance from day one.
<\!-- SECTION 9 — CONCLUSION -->

9. Conclusion

The OBBBA did not end commercial energy incentives — it compressed them. The window is narrower, the deadlines are harder, and the complexity of navigating what remains has increased significantly. But for commercial building owners who act with urgency and structure their projects correctly, the surviving incentives still represent extraordinary economics.

A well-structured commercial solar project with domestic content, prevailing wage compliance, and MACRS depreciation can still recover 60% or more of project cost in first-year tax benefits and incentives. The July 4, 2026 construction-start deadline is not a soft suggestion — it is the line between capturing these economics and losing them permanently.

The critical actions are the same whether you manage one commercial building or a portfolio of fifty: identify eligible properties, model the incentive stack with a qualified professional, and initiate construction before the deadline. The time to start that process is now.