One Big Beautiful Bill Act (OBBBA) Quick Guide for RE100 Buyers
Why This Matters for RE100 Companies
The One Big Beautiful Bill Act (OBBBA), passed July 4, 2025, introduces sweeping changes to clean energy incentives and sourcing requirements. For RE100 members, these changes come at a critical time, with new technical criteria requiring:
- Projects to be commissioned within 15 years of claim year
- Enhanced environmental and sustainability standards for eligible generation
OBBBA changes the rules - and the timeline – for accessing federal tax credits, building compliant renewable portfolios, and meeting climate targets on time.
Key Policy Changes Under OBBBA
- PTC/ITC Credit Phaseout Accelerated
Projects must start construction by July 4, 2026 for a four-year construction window or be in service by December 31, 2027 to qualify for any federal clean energy tax credits (PTC/ITC). - FEOC Sourcing Restrictions
Project starting construction after January 1, 2026, must comply with strict rules for tracking the origin of each component in the project and not exceed thresholds for using equipment or components from "Foreign Entities of Concern" to be eligible for credits. - Bonus Depreciation Extended
100% bonus depreciation available for qualifying projects placed in service after January 19, 2025. - IRS Released New “Beginning of Construction” Guidance for Wind and Solar
The IRS released new guidance on August 15 that narrows the path for developers to claim beginning of construction for tax credit purposes. Importantly, the guidance maintains pathways for developers to claim beginning of construction through the “physical work” test and maintains the four-year construction window for projects that start construction prior to July 6th, 2026.
Implications for RE100-Aligned Procurement
- RE100 15-Year Rule + OBBBA Timelines = 30-Month Sprint
To remain compliant and capture full value, projects should be executed within the 2025–2027 window. - Developer Response Already Underway
Developers are pausing deals, repricing PPAs (10–15% increases), and revalidating equipment sourcing to ensure compliance. - Inventory Compression Likely
Eligible projects will become harder to secure. Delays could lead to either noncompliance with RE100 or higher costs.
Trio’s Recommendations
- Revalidate all active and planned RE100-aligned procurements against new criteria
- Prioritize new-build projects with construction start dates by the end of 2025
- Engage in due diligence on project sourcing to mitigate FEOC risk
- Accelerate internal approvals and execution plans to meet OBBBA deadlines
Need Support? Book a private advisory session with Trio’s Policy and Clean Energy experts:
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