Project Developers & Owners
As a clean energy developer, you are managing a growing set of compliance obligations across your projects: Foreign Entity of Concern (FEOC), Prevailing Wage & Apprenticeship (PWA), Domestic Content, Beginning of Construction (BOC), and state-level prevailing wage and labor compliance. A gap in any one of them carries real financial consequences: recapture, credit reduction, or penalties, depending on the obligation. Empact manages each obligation across your full project portfolio, from the first day of construction through the full tax credit lifecycle.
0.0
compliance issues per contractor per week identified by Empact
5 yr
ITC recapture window per Qualified Facility
Why It Matters
The Inflation Reduction Act created one of the most complex compliance infrastructures in the history of clean energy finance, and most project teams weren't built to manage it. FEOC, PWA, Domestic Content, BOC, and 48E requirements each carry independent deadlines, documentation obligations, and recapture risk. Tax equity investors and credit buyers require audit-ready records before deals close.
Empact's platform identifies an average of 1.6 compliance issues per contractor per week. Many are caught and corrected in real time. Without active monitoring, issues compound, and the documentation needed to resolve them cannot be reconstructed after the fact.
Core Obligations on Each Project
Risk by Project Lifecycle Stage
Where each obligation hits, and what's at risk
| Stage | Primary obligation | What can go wrong |
|---|---|---|
| Pre-Construction | BOC, FEOC | BOC date not established with defensible Physical Work or 5% Safe Harbor evidence; supplier FEOC certificates fail IRS Notice 2026-15 standards. |
| Construction | PWA, State PW, Domestic Content | Contractor wage and apprentice records incomplete under federal and state prevailing wage rules; manufactured-product cost data not captured at the Qualified Facility level before procurement closes. |
| Pre-PIS | All obligations | Tax equity diligence opens documentation gaps that delay close, reduce credit value at transfer, or trigger pricing concessions. |
| Operations & Recapture | PWA, FEOC | Repairs and alterations performed without prevailing wage compliance trigger recapture; FEOC restrictions tightened year-over-year may impact O&M supply chains. |
Real-Time Risk Management
Empact's platform and expert team proactively identify and resolve compliance issues during construction, averaging 1.6 issues per contractor per week, before they reach your counsel or your investors.
Audit-Ready Documentation
Empact compiles comprehensive compliance reporting and audit materials across each requirement from day one, so your records are defensible at due diligence and for the full tax credit lifecycle.
Continuous Monitoring
Empact monitors compliance through the full ITC recapture period, so compliance issues that arise during operations and maintenance are caught before they become a surprise.
The Empact Developer Engagement
Portfolio Kickoff
Scope each project and obligation, define work breakdown structures, and align with your tax counsel.
Baseline & Plan
Assess in-flight projects, identify pre-existing gaps, and stand up tracking before mobilization.
Live Tracking
Capture PWA payroll, Domestic Content procurement, and FEOC supplier evidence in real time.
Issue Remediation
Resolve the 1.6 issues per contractor per week as they emerge, before they reach diligence.
Pre-PIS Certification
Deliver audit-ready compliance files at the Qualified Facility level for tax equity diligence.
Recapture Monitoring
Monitor each project through the full ITC recapture window, so O&M never produces a surprise.
Recent Regulatory Updates
August 2022
Inflation Reduction Act enacted
Created the modern PWA, Domestic Content, BOC, and 48E framework, plus credit transferability under Section 6418.
January 2025
Section 48E takes effect
Projects beginning construction on or after January 1, 2025 fall under the tech-neutral 48E framework, with compliance measured at the Qualified Facility level.
August 2025
OBBBA reshapes the landscape
The One Big Beautiful Bill Act introduced FEOC supply-chain restrictions and additional documentation requirements for projects beginning construction after August 2025.
February 2026
IRS Notice 2026-15 on FEOC
Treasury and IRS released detailed guidance on what FEOC certifications must contain. Many supplier-provided certificates fail the new standards.
Ongoing
Treasury rulemaking
Treasury continues to issue final regulations on PWA, Domestic Content, and 48E. Empact integrates each clarification into ongoing engagements.
Who Empact Works With
Empact engages across asset classes and ownership structures, and tailors the engagement to the way each operator builds and runs their portfolio.
IPPs
Independent power producers and aggregators managing diverse portfolios across geographies and asset classes.
Utility-Scale Solar
Multi-hundred-MW project portfolios with complex contractor stacks and high tax credit exposure per facility.
Wind Developers
Onshore and offshore facilities, where Qualified Facility-level documentation lines up with each turbine.
Storage Developers
Standalone and hybrid BESS, including paired solar-plus-storage with overlapping 48E and Domestic Content scopes.
Distributed Generation
C&I and community solar fleets, where compliance is duplicated across many small Qualified Facilities.
Industries We Serve
Why Empact
Empact's team combines legal, technical, and regulatory expertise built specifically for the clean energy market, so your project's compliance obligations are identified earlier, documented to audit standard, and defensible when tax equity counsel and credit buyers come to the table.
We don't hand you a checklist. NexusIQ, Empact's AI-native compliance platform, conducts the review, organizes the documentation, and delivers certifications your tax counsel can rely on.
Empact supports developers through the full 5-year ITC recapture window, so compliance issues that arise during operations and maintenance are caught before they become a surprise.
Related Insights
Empact works alongside your team and counsel from the first day of construction through the full tax credit lifecycle, so your credits are protected at each stage.
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