EPCs, Contractors & Suppliers
As an Engineering, Procurement, and Construction (EPC) firm, specialty subcontractor, or supplier, you carry direct compliance obligations under the Inflation Reduction Act (IRA) and the One Big Beautiful Bill Act (OBBBA). Prevailing Wage & Apprenticeship (PWA) requirements apply to each laborer and mechanic on your project, across each tier of your contractor network. Foreign Entity of Concern (FEOC) rules add another layer for suppliers, and Domestic Content documentation depends on what your supply chain can certify. Empact works directly with you and your subcontractors to collect, validate, and document certified payroll and supplier records from day one, so compliance issues are resolved before they become penalties.
0.0
compliance issues per contractor per week identified by Empact
Weekly
certified payroll validation cadence
5 yr
ITC recapture window post placed-in-service
Why It Matters
Under the Inflation Reduction Act, prevailing wage obligations apply to each laborer and mechanic on your project, including subcontractors at each tier. If a subcontractor in your network fails to pay prevailing wages or meet apprenticeship ratios, your project's full credit rate is at risk. PWA compliance is what qualifies your project for the full 30% Investment Tax Credit (ITC) or prevailing Production Tax Credit (PTC) rate. Unresolved issues become penalties automatically under the regulations, and cure payments compound quickly when caught after the fact.
Empact works directly with you and your subcontractor network to collect certified payroll weekly, identify issues in real time, and resolve them before they become penalties, averaging 1.6 issues resolved per contractor per week.
Your Obligations
How Empact Embeds Into Your Workflow
Without Empact vs. With Empact
| Without Empact | With Empact | |
|---|---|---|
| Payroll review cadence | Monthly batch review, often during slower weeks for the back office. | Weekly certified payroll collection and validation from each contractor and subcontractor. |
| Issue identification | Wage rate and ratio errors surface in quarterly or end-of-project audits. | Issues flagged within days, with the cure path documented in real time. |
| Cure payment exposure | Underpayment windows are months long, multiplying the cure amount and penalty interest. | Underpayment windows are days long, keeping cure amounts manageable. |
| Subcontractor coordination | Compliance chases each subcontractor separately, often after issues compound. | Subcontractors onboarded into a defined cadence at project kickoff, before mobilization. |
| Supplier FEOC certificates | Suppliers provide whatever certificate they have on hand, often failing IRS standards. | Supplier intake checklist aligned to IRS Notice 2026-15, with deficient certificates flagged before procurement closes. |
| Developer handoff at PIS | Scramble to assemble compliance records, gaps slow tax equity diligence. | Audit-ready file at Qualified Facility level, ready for counsel and credit buyer review. |
Certified Payroll Collection
Empact collects, reviews, and validates certified payroll records from each contractor and subcontractor on a weekly basis, identifying wage rate errors, apprenticeship ratio gaps, and missing documentation before issues become penalties.
Subcontractor Onboarding
Before construction begins, your subcontractors are onboarded into NexusIQ, with data collection workflows, compliance requirements, and reporting cadences established from day one. You start the project with your network aligned, not catching up.
Real-Time Issue Resolution
When Empact identifies a compliance issue, our team works directly with you to resolve it in real time, documenting the cure and maintaining the audit trail the developer's counsel and tax equity investors require.
The Empact EPC & Contractor Engagement
Onboarding & WBS Setup
Map the work breakdown structure to Qualified Facilities and define the data exchange with each subcontractor.
Wage Determination
Validate Davis-Bacon wage determinations and confirm coverage of each labor classification on the project.
Apprentice Plan
Stand up the apprenticeship ratio plan and confirm registered apprenticeship sponsors.
Weekly Payroll Collection
Collect and validate certified payroll from each contractor and subcontractor each week.
Real-Time Resolution
Resolve the 1.6 issues per contractor per week as they emerge, documenting each cure.
PIS Handoff
Deliver an audit-ready compliance file at the Qualified Facility level to the developer's counsel.
Recent Regulatory Updates
January 2023
PWA effective date
Prevailing Wage and Apprenticeship requirements took effect for projects beginning construction on or after January 30, 2023.
June 2024
Treasury final PWA regulations
Treasury issued final regulations clarifying Good Faith Effort documentation, ratio tracking, and cure mechanics for PWA compliance.
August 2025
OBBBA supplier rules
The One Big Beautiful Bill Act introduced expanded supplier-side FEOC restrictions and certification requirements that EPCs and contractors must collect from upstream suppliers.
February 2026
IRS Notice 2026-15 on FEOC
Treasury and IRS released detailed guidance on what supplier FEOC certifications must contain. Many off-the-shelf certificates fail the new foundational standards.
Ongoing
Davis-Bacon wage updates
The Department of Labor publishes updated wage determinations on a rolling basis. Empact reconfirms applicable rates at each weekly payroll cycle.
Who Empact Works With
Empact engages across the EPC, contractor, and supplier network and tailors the engagement to the way each operator runs their work.
EPCs
Engineering, procurement, and construction firms running utility-scale and DG project portfolios.
Specialty Subcontractors
Electrical, structural, civil, and mechanical contractors at each tier of the construction stack.
Module & Inverter Suppliers
Manufactured-product suppliers providing FEOC certifications and Domestic Content cost data per Qualified Facility.
Steel & Iron Suppliers
Structural steel and iron suppliers attesting to 100% US manufacture for the Domestic Content rule.
Apprenticeship Sponsors
Registered apprenticeship programs supplying qualified apprentice hours to meet PWA ratio requirements.
Why Empact
Empact embeds into your construction workflow, collecting certified payroll weekly, flagging issues in real time, and coordinating resolution across your full subcontractor network.
Empact organizes and maintains the complete certified payroll audit trail from day one, so when due diligence comes, your records are ready.
Empact resolves compliance issues before they escalate, protecting your contractor relationships and your standing on future projects.
Related Insights
Empact works directly with you and your subcontractor network to manage certified payroll, FEOC supply chain requirements, and each compliance obligation in between, so issues are resolved before they become penalties.
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