On July 4, President Trump signed the “One Big Beautiful Bill” (OBBB) into law, a sweeping reconciliation package that redefines the rules of the game for renewable energy developers, financiers, and manufacturers. On July 7, the administration followed up with an executive order directing the Treasury to issue new guidance on construction-start criteria and FEOC enforcement within 45 days.

We’ve combed through top legal memos, tax credit guidance, and industry webinars to bring you a concise roundup of what’s changing, what’s staying, and how teams can adapt.

The TL;DR

• Accelerated timelines for wind and solar. To remain eligible for full tax credit value under Sections 45Y and 48E, projects must begin construction by July 4, 2026, or be placed in service by the end of 2027.
• FEOC rules are here, and they’re strict. Projects must now meet stringent restrictions related to foreign ownership, sourcing, and contractual control, especially in relation to Chinese entities.
• Longer runway for storage and emerging technologies. Projects like standalone storage, geothermal, and hydropower can qualify for full tax credits through 2033, with a phased reduction beginning in 2034.
• Transferability survives. The ability to transfer tax credits to third parties remains intact, supporting continued liquidity in tax equity markets.
• Impending Treasury guidance. On July 7th, an executive order was directed to the U.S. Treasury to revisit and potentially restrict “beginning of construction” rules, adding further complexity and uncertainty to project planning.

What This Means for Developers

1. Project schedules must adapt. If you’re planning to break ground in 2025 or 2026, the race is on. But rushed compliance could work against you as the safe harbor rules may change shortly. Set yourself up for the highest chance of success by staying hyper-focused on achieving your portfolio’s near-term development milestones.
2. Audit your supply chain. The new FEOC restrictions require a careful audit of supplier relationships, licensing terms, and financing arrangements – particularly those involving foreign entities. Organized documentation is critical.
3. Strategic opportunities for non-solar/wind assets. Technologies outside the core solar and wind categories, particularly storage, have a more favorable policy horizon and fewer immediate compliance burdens.
4. Stack smart. Manufacturers can still stack 45X credits, but only if integration happens in the same facility and 65%+ of material costs are domestic.

‍

BuildQ POV

The OBBB reshapes where and how risk shows up in the development process. The start date of construction, structure of financial participation, and details of your procurement agreements now materially affect tax equity eligibility.

BuildQ helps clean energy teams stay ahead of these shifts. With AI-powered document intelligence and live risk tracking, you can:

• Flag FEOC-related terms across contracts
• Identify key dates and documentation relevant to construction-start eligibility
• Build investor-ready data rooms in record time

What’s Next

• Expect new Treasury guidance on construction rules by mid-August.
• Watch for IRS updates on FEOC compliance documentation.
• Gear up for a mid-2026 industry bottleneck as developers scramble to start construction before deadlines.