New Year, New Rules: Sunsetting the Solar ITC (48E)

This July 4th will carry a different meaning for the solar industry. It marks the beginning of the countdown—not just to build a solar array, but to have it fully operational.

The One Big Beautiful Bill (OB3) has accelerated the original phaseout timeline for the Investment Tax Credit (ITC) under Section 48E, moving it up from 2036 and creating urgency across the market. Developers, EPCs, and asset owners are now evaluating how to preserve eligibility—and how to effectively “Safe Harbor” upcoming projects.

Key Dates to Remember:

Construction begins BEFORE July 5, 2026:
Projects must be placed in service by December 31, 2030.

Construction begins ON OR AFTER July 5, 2026:
Projects must be placed in service by December 31, 2027.

The window is tightening. Planning and procurement strategies must adjust accordingly.

New Rules for 2026: FEOC Requirements

As if the accelerated timeline wasn’t enough, new Foreign Entity of Concern (FEOC) rules will significantly impact equipment sourcing.

To qualify for the ITC:

Projects must not include materials, components, or assistance from any FEOC-designated country.

This primarily affects products sourced from China, currently the world’s largest producer of solar PV equipment.

Compliance standards will become increasingly strict each year starting January 1, 2026.

These evolving restrictions will require careful supply chain evaluation and documentation to maintain eligibility.

Safe Harbor Solution: Accord Power Inc

Accord Power can provide a full project proposal outlining the most strategic path forward to:

Maximize ITC value; Preserve eligibility under the new timelines

Structure a compliant Safe Harbor strategy; Protect up to 30% of total project cost

If you have a project and want to secure your position before the deadlines tighten, reach out to Ryan Pascucci at Accord Power to explore potential Safe Harbor solutions.

Disclaimer: This material is provided for informational purposes only and does not constitute tax, legal, or financial advice. Accord Power Inc. does not provide tax or legal advisory services. Readers should consult their own qualified tax, legal, and financial advisors regarding the applicability of any incentives, including the Investment Tax Credit (ITC) and Foreign Entity of Concern (FEOC) requirements, to their specific circumstances.