Home › §48E ITC transfers
§48E Bonus Credits: Prevailing Wage, Energy Community and Domestic Content
A §48E credit can be 6%, 30% or more of project cost, depending on wage rules and bonuses. A buyer buying "a credit" should know which rate the seller is claiming and how it is proved, because a failure lowers the credit amount and, if the buyer bought the larger amount, creates an excess credit problem.
How the rate builds
| Layer | Effect | Condition (IRS; §48E) |
|---|---|---|
| Base rate | 6% of qualified investment | Qualified facility or storage placed in service after 2024 |
| Prevailing wage and apprenticeship | Up to 30% (5x the base rate) | Meets the wage and apprenticeship rules, or the project is under 1 MW AC, or construction began before the cutoff date set by the statute |
| Energy community | +10 points (+2 on the 6% base rate) | Placed in service in an energy community (brownfield, certain statistical areas with fossil-fuel employment or coal-related closures) |
| Domestic content | +10 points (+2 on the 6% base rate) | Steel, iron and manufactured products meet the adjusted percentage |
| Low-income communities | Additional points for certain small projects | Requires an IRS capacity allocation; ask for the letter |
For example, a project at 30% with the energy community and domestic content bonuses would be at up to 50% (30 + 10 + 10), per the IRS description. Many projects have one bonus or none, so do not assume the top rate.
Evidence to request
- Prevailing wage and apprenticeship: certified payroll, apprentice ratios and labor-hour records, plus any cure payments. If a project fails, the multiplier can be lost; Crux says a prevailing wage failure during the five-year period can also recapture the increased amount (with a cure window).
- Energy community: the IRS list or map category the site falls into, and the date it was tested (energy community guide; Notice 2023-29; map guide).
- Domestic content: manufacturer certifications and the safe-harbor tables in Notice 2023-38 (domestic content guide). For §48E the required adjusted percentage depends on when construction began: 40% (before June 16, 2025), 45% (June 16 to Dec. 31, 2025), 50% (2026) and 55% (after 2026), per the statute.
Why buyers care
The more bonuses a credit carries, the more diligence it needs and the more you depend on the seller's indemnity. Ask each seller which rate it is claiming, how it proves each layer, and what happens to your price if a layer fails. Our diligence checklist and agreement terms guide cover this.
Back to the §48E buyer guide.
Frequently asked questions
What is the maximum §48E credit rate?
The IRS describes a 6% base, up to 30% with prevailing wage and apprenticeship requirements, plus 10 percentage points each for domestic content and for an energy community. That totals up to 50% for a project that meets all of them, before any low-income communities adder.
What if a project fails the prevailing wage rules?
It can lose the multiplier and fall back to the base rate unless the failure is cured under the rules. Buyers should require records and an indemnity covering credit loss.
How is an energy community proven?
By showing the site falls in a brownfield site, a statistical area with qualifying fossil-fuel employment, or a coal-closure census tract using the IRS lists and notices such as Notice 2023-29. The seller should document the category and the date tested.
What domestic content percentage applies?
For §48E, the adjusted percentage is 40% for construction beginning before June 16, 2025, 45% from then through 2025, 50% in 2026 and 55% after 2026, according to the statute.
- 26 U.S.C. §48E, Clean electricity investment credit (Cornell LII)
- IRS: Clean Electricity Investment Credit (§48E)
- 26 CFR §1.48E-1, Definition of energy property and rules applicable to the energy credit (eCFR)
- IRS Notice 2023-29, energy community bonus credit amounts
- IRS Notice 2023-38, domestic content bonus credit guidance
- Crux: What is recapture risk in tax credit transactions? (Aug. 26, 2026), third-party market data