What the New Federal Budget Bill Means for Clean Energy Buyers

A sweeping new federal budget bill, unofficially called the “Big, Beautiful Bill,” has the potential to reshape clean energy market dynamics. While developers may be focused on construction timelines and credit eligibility, clean energy buyers should also pay close attention to how this legislation may impact future procurement opportunities. If your organization has 2030 decarbonization goals, it is imperative to move quickly to secure renewable energy certificates (RECs) and renewable purchase power agreements (PPA and VPPA).
Early Projects Are More Valuable
Projects that commence construction within 12 months of the bill’s enactment will be eligible for 100% of the IRA’s 45Y production or 48E investment tax credits. These credits improve project economics significantly and can reduce the cost of energy for buyers through power purchase agreements or similar contracts.
However, a new executive order from President Trump adds uncertainty by directing the U.S. Treasury to revise safe harbor rules within 45 days. Buyers should inquire about how project sponsors plan to preserve eligibility under the changing guidance.
Without these tax incentives, PPA prices can increase by at least 20%.
2025 Is the Cleanest Window
Buyers looking to secure favorable pricing and lower regulatory risk may find 2025 to be the optimal year for the contract. Projects that start next year will avoid:
- Uncertainty around placed-in-service deadlines
- New foreign content restrictions under the bill’s Foreign Entity of Concern (FEOC) rules
These restrictions would increase future project costs and limit access to key clean energy components, particularly in the solar and storage sectors.
Impact on REC Procurement:
The reduction and early sunset of key incentives is expected to slow the development of new wind and solar projects, major sources of Renewable Energy Certificates (RECs). As project development declines, REC supply may tighten. At the same time, ongoing state Renewable Portfolio Standards (RPS) will continue to drive demand, likely resulting in upward pressure on REC prices. Green-e REC prices are relatively low currently, but EnerNova forecasts prices to rise as incentives righten and sunset. Organizations considering future purchases will benefit from locking in current rates.

Timing Gets Tricky After 2025
Projects that begin more than 12 months after the bill’s enactment must be operational by the end of 2027 to qualify for tax credits. Starting in 2028, the 45Y and 48E credits for wind and solar begin to sunset, which could raise buyer costs or shift procurement strategies toward other technologies.
Planning Around a Broader Portfolio
For buyers diversifying into clean technologies beyond wind and solar, there is some flexibility. Carbon-free technologies such as energy storage, nuclear, and hydropower will remain eligible for full tax credits if construction begins by the end of 2033.
Supply Chain Considerations
The bill also makes major changes to the 45X advanced manufacturing credit. This credit has driven a surge in U.S. clean energy manufacturing announcements, but going forward:
- It will be subject to FEOC content rules
- Credits for critical minerals will begin a 25% phasedown starting in 2031
These provisions could affect the long-term cost structure of clean energy technologies commonly used in corporate and institutional procurements. The New Budget Bill does preserve the transferability of tax credits, providing buyers and financiers with greater flexibility to structure and monetize clean energy deals.
What Buyers Should Be Asking Now
The next wave of clean energy projects will be shaped by how developers respond to this legislation. Projects that begin construction in 2025 are expected to carry fewer policy risks, stronger financial support, and potentially more attractive pricing.
Buyers should be asking:
- Is the project eligible for full tax credit value?
- Will it meet the safe harbor and service deadlines?
- Does it rely on components or materials that may be restricted under new rules?
EnerNova is monitoring the evolving guidance and stands ready to help buyers assess risk, optimize timing, and take advantage of this narrow but powerful window for action.