BOC Compliance

Miss your BOC date and the tax rules you planned around may not apply.

The One Big Beautiful Bill Act introduced new Beginning of Construction deadlines and documentation requirements for clean energy projects. Empact documents, certifies, and monitors your BOC date, so the tax rules governing your project are locked in before the window closes.

What's at Stake

Your BOC date determines which tax rules govern your project, and you can't reconstruct it after the fact.

Empact certifies your BOC date and locks in the tax rules that govern your project, documented and defensible before the window closes.

Tax Rule Lock-In

The rules that govern your project are set at BOC.

The tax credit rules that apply to your project, the credit rate, the multipliers, the FEOC requirements, are locked in at Beginning of Construction.

Evidence Window

Documentation must be captured in real time.

Timecards, certifications, and physical work evidence must be captured during construction. This information is often unavailable by the time it's needed, months after a contractor has finished with the project.

FEOC Grandfathering

Safe harbor only counts if BOC is properly documented.

Projects that safe-harbored before key deadlines may avoid certain FEOC requirements entirely, but only if their BOC status is properly documented.

Key Deadlines

The OBBBA introduced new BOC deadlines that clean energy developers need to know.

July 4, 2026

Solar & Wind

Begin construction by July 4, 2026 to avoid the 12/31/2027 placed-in-service deadline.

Solar and wind projects that begin construction by July 4, 2026 are not subject to the December 31, 2027 placed-in-service deadline. Projects beginning construction after July 4, 2026 must be placed in service by December 31, 2027 to qualify for tax credits.

Dec 31, 2025

Passed

Projects that began construction by December 31, 2025 avoided the most challenging FEOC material assistance requirements.

Projects that began construction before January 1, 2026 may avoid certain Foreign Entity of Concern requirements. Confirming grandfathered status requires proper BOC documentation.

Aug 2025

Physical Work Test

Solar and wind projects over 1.5 MW must use the physical work test from August 2025.

The 5% safe harbor is no longer available for solar and wind projects over 1.5 MW beginning construction after August 2025. Significant physical work must be documented and defensible.

How BOC Is Established

Your project must satisfy one of two tests to establish its Beginning of Construction date.

Physical Work Test

Significant physical work must be documented from BOC through placed-in-service.

Insufficient documentation of significant physical work, whether on-site or off-site, can void your BOC claim. Timecards, contracts, and work evidence must be collected and preserved throughout construction.

5% Safe Harbor

Qualifying expenditures of at least 5% of total project cost must be incurred at BOC.

Falling below 5% of eligible capital expenditures on your BOC date forfeits safe harbor, and the tax rules that come with it. Not available for solar and wind projects over 1.5 MW beginning construction after August 2025.

Empact turns your BOC date into a defensible, certified compliance record.

Document & Certify

Collection of physical work evidence, timecards, and contracts, certified and defensible for formal tax opinions on your BOC date.

Track the 5% Threshold

Monitor bills of materials throughout construction and certify that safe harbor was met at the BOC date and maintained through placed-in-service.

Monitor Continuity

Flag projects at risk of missing the 4-year continuity window before it becomes a problem. Empact works with your team to address continuity issues early, so your BOC status holds from start to placed-in-service.

Your BOC date is only as strong as the documentation behind it.

Evidence must be captured during construction, not after.

BOC evidence must be captured in real time. You can't reconstruct it after a contractor leaves the site. Compliance approaches that rely on periodic reviews find gaps too late. Empact collects and organizes documentation as construction progresses, so your record is complete when your counsel needs it.

Built for the complexity of clean energy compliance.

We don't hand you a checklist. We conduct the review, organize the documentation, and deliver a BOC certification your tax counsel can rely on.

Connected to your full compliance picture

BOC status affects FEOC exposure, PWA requirements, and placed-in-service deadlines. Empact manages all six compliance areas from a single platform, so your deadlines and requirements are managed in one place.

What Empact Delivers

Everything your tax counsel, investors, and insurers need, delivered audit-ready.

Physical work evidence collected and organized by project

5% safe harbor monitored and certified at placed-in-service

BOC date established and defensible for formal tax opinions

BOC evidence sourced from original timecards, contracts, and on-site records, not reconstructed after the fact

Continuity monitored through placed-in-service

Documentation package ready for IRS scrutiny and tax equity diligence

The BOC window closes fast. Let's make sure your documentation is audit-ready.

Empact's BOC team is ready to begin collecting physical work evidence, reviewing your documentation, and delivering a certified compliance record.

Talk to Our BOC Team