Partners
Accounting firms, law firms, tax credit marketplaces, and insurance underwriters all play a role in clean energy tax credit transactions. Empact works alongside your team, delivering the certifications, reliance letters, audit materials, and ongoing compliance monitoring your clients require, across PWA, FEOC, and Domestic Content. Our work is validated through Agreed Upon Procedures (AUP) by Big 4 firms, structured to satisfy the diligence standards of leading financial and legal advisors.
$0B
in clean energy tax credits created by the IRA
5 yr
ITC recapture window post placed-in-service
0.0
compliance issues per contractor per week identified by Empact
Why It Matters
Each clean energy tax credit transaction depends on documented compliance across FEOC restrictions, PWA requirements, Domestic Content thresholds, BOC deadlines, and Section 48E obligations. A gap in any one of them creates recapture risk that may fall on your client. Accounting firms, law firms, and marketplaces are increasingly expected to vet compliance documentation as part of transaction due diligence, and the consequences of missing a gap after close are severe.
Empact delivers third-party certifications, reliance letters, and audit-ready documentation structured to satisfy the standards of leading financial and legal advisors. Our work is validated through Agreed Upon Procedures (AUP) from Big 4 firms.
What You Get
Independent compliance certifications across PWA, FEOC, Domestic Content, and Section 48E that your counsel and counterparties can cite in their own opinions.
Reliance letters structured for tax counsel, tax equity investors, transferability buyers, and insurance underwriters, with the scope and limitations clearly defined.
Audit-ready documentation backed by Big 4 Agreed Upon Procedures engagements over our compliance methodology, organized at the Qualified Facility level.
Compliance monitoring across the full ITC recapture window (5 years) or PTC credit term (10 years), so operational issues are caught and cured, not surfaced at audit.
Why Partners Choose Empact
Without Empact vs. With Empact
| Without Empact | With Empact | |
|---|---|---|
| Due diligence | Documents chased piecemeal from the developer, EPC, and supplier list. | Turnkey compliance file delivered at the Qualified Facility level, indexed for diligence. |
| Reliance basis | Counsel's opinions rest on developer-prepared schedules and self-attestations. | Independent, third-party certifications backed by Big 4 AUP-validated methodology. |
| Closing timeline | Opinions and underwriting held up by missing certifications or supplier gaps. | Counsel can issue opinions based on documented, audit-ready deliverables. |
| Post-close monitoring | Limited ongoing visibility, surprise recapture risk if operations drift. | Continuous monitoring across the ITC recapture or PTC term, with issues flagged and cured. |
| Firm exposure | Your firm is the last line of defense if a compliance gap is missed. | Insurance-backed certifications and a full compliance record at your fingertips. |
Who We Serve
Whether your firm leads the engagement or supports a counterparty, Empact's deliverables are structured to fit the standards your work is held to.
Accounting Firms
Compliance documentation that supports cost segregations, appraisals, and tax credit transactions, validated through Big 4 AUP engagements.
Law Firms
Certifications and audit trails tax counsel needs to issue reliance letters and tax opinions for tax equity and transferability transactions.
Tax Credit Marketplaces
Standardized compliance packages marketplaces can surface to buyers as part of pre-close diligence, accelerating transferability deal flow.
Insurance
Underwriting and claims support for tax credit insurance across PWA, FEOC, Domestic Content, BOC, and Section 48E obligations.
Tax Equity Investors
Independent diligence support for tax equity transactions, with monitoring through the ITC recapture or PTC term to protect the investment.
How Empact Engages Partners
Engagement Kickoff
Align on the transaction, the parties involved, and the deliverables your firm and your client require.
Scope & Data Room Setup
Define the compliance scope by Qualified Facility, identify the documentation owners, and stand up the secure data room.
Compliance Review
Review certified payroll, supplier FEOC certifications, Domestic Content cost data, and BOC evidence against IRS standards.
Reliance Deliverables
Issue third-party certifications, reliance letters, and the AUP-validated audit package your counsel can cite.
Ongoing Monitoring
Monitor compliance through the ITC recapture window or PTC term, flagging and curing operational issues as they emerge.
Recent Regulatory Updates
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.
August 2025
OBBBA supplier rules
The One Big Beautiful Bill Act introduced expanded supplier-side FEOC restrictions and certification requirements affecting credits across the IRA framework.
June 2024
Treasury final PWA regulations
Treasury issued final regulations clarifying Good Faith Effort documentation, ratio tracking, and cure mechanics for PWA compliance.
April 2024
Transferability final regulations
Final regulations on Section 6418 transferability clarified seller obligations, buyer diligence expectations, and the recapture allocation between parties.
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.
Why Empact
Empact's certifications and reliance letters are structured to satisfy the due diligence standards of leading tax equity investors, credit buyers, law firms, and accounting firms, so your team can close with confidence.
We don't hand you a checklist. Empact conducts the review, organizes the documentation, and delivers certifications your tax counsel can rely on.
Empact monitors compliance through the ITC recapture window (5 years) or the PTC credit term (10 years), so issues that arise during operations are caught before they become a surprise recapture event for your client.
FAQ
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Empact delivers the certifications, reliance letters, and audit materials your transactions require.
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