Home › §48E ITC transfers
§48E Eligible Technologies Beyond Solar: Storage, Wind, Geothermal and More
Quick answer
§48E is technology-neutral: qualified zero-GHG electricity facilities and energy storage technology placed in service after Dec. 31, 2024 may qualify. IRS Pub. 6045 examples include wind, solar, hydropower, energy storage (such as batteries), marine and hydrokinetic, nuclear, geothermal and certain waste energy recovery property. OBBBA shortened the runway for new wind and solar; storage and other listed technologies are not under that same early wind/solar cutoff. Confirm eligibility with your CPA.
The §48E clean electricity investment credit is technology-neutral: a qualified facility can earn the credit when its greenhouse gas emissions rate for electricity production is not greater than zero, and energy storage technology is separately eligible. Solar is only one path. This page summarizes the technology categories IRS and Treasury materials list, the wind and solar timing rules added by the One Big Beautiful Bill Act, and what buyers should verify before a §6418 purchase.
How §48E decides what qualifies
Under IRS: Clean Electricity Investment Credit, §48E is an emissions-based, technology-neutral investment credit for qualified facilities and energy storage technology placed in service after December 31, 2024. Taxpayers generally claim it on Form 3468. You cannot claim both the investment credit and the production credit for the same facility.
Treasury and the IRS published final rules for §§45Y and 48E (Federal Register, Jan. 15, 2025). A Treasury release describing those rules states that they clarify which zero-emissions technologies qualify, including wind, solar, hydropower, marine and hydrokinetic, geothermal, nuclear, and certain waste energy recovery property, and that combustion and gasification technologies are addressed through lifecycle analysis rules rather than a fixed equipment list.
Separately, the statute allows a credit for energy storage technology (see 26 U.S.C. §48E(a)(1)(B) and §48E(c)), using the §48(c)(6) definition with a stated exception. Storage is not required to be co-located with generation.
Technologies called out in IRS Pub. 6045
IRS Publication 6045 (elective pay / ITC overview for tax-exempt and governmental entities) says the §48E credit is technology-neutral and lists examples under the final §48E regulations:
- Wind energy property
- Solar energy property
- Hydropower
- Energy storage (such as batteries)
- Marine and hydrokinetic
- Nuclear
- Geothermal
- Certain types of waste energy recovery property
Those are examples, not a closed catalog. A facility that meets the statutory emissions and other requirements can qualify even if it is not on a short list; conversely, appearing on a list does not replace diligence on placed-in-service timing, emissions modeling, FEOC rules or recapture.
Beyond solar: what buyers usually see
| Category | Buyer notes (educational) |
|---|---|
| Energy storage | Expressly eligible under §48E. Not subject to the OBBBA wind/solar early cutoff described below. Dedicated guide: §48E energy storage for buyers. |
| Wind | Listed in Pub. 6045 and Treasury materials, but subject to OBBBA construction / placed-in-service timing. See solar and wind deadlines. |
| Geothermal (electricity) | Listed among §48E examples. Confirm emissions and facility definition with advisors; geothermal heat pumps are treated under the legacy §48 discussion in Pub. 6045, not as a §48E example. |
| Hydropower; marine and hydrokinetic | Listed among §48E examples in Pub. 6045 and Treasury’s summary of the final rules. |
| Nuclear | Listed among §48E examples for new zero-emissions generation. Existing nuclear production incentives (such as §45U) are a different credit. |
| Waste energy recovery (certain types) | Called out as a §48E example category; exact property must meet the regulations. |
Third-party market reports (not IRS guidance) have shown storage taking a larger share of transferable volume in 2026. Supply mix changes; it is not a promise of availability or price. Start with the §48E buyer guide for rates, pricing, diligence and transfer steps.
OBBBA timing: wind and solar vs other technologies
Public Law 119-21 (the One Big Beautiful Bill Act, signed July 4, 2025) added earlier cutoffs for wind and solar under §48E/§45Y: generally, those facilities keep the credit only if construction began by July 4, 2026, or the facility is placed in service by December 31, 2027. IRS Notice 2025-42 addresses beginning-of-construction for that deadline. Energy storage is carved out of that wind-and-solar termination in the statute’s structure as described in our OBBBA summary and storage guide.
For technologies other than wind and solar, the IRS Clean Electricity Investment Credit page describes a phase-out that starts for the later of 2032 or when U.S. greenhouse gas emissions from electricity fall to 25% of 2022 levels. Confirm the current statutory phase-down percentages with your advisors before modeling long-dated inventory.
FEOC and foreign-entity restrictions buyers ask about
OBBBA also tightened foreign-entity rules for several credits, including §48E. In brief (details belong in counsel’s memo): specified foreign entities and related concepts can bar claiming or transferring certain credits, and material-assistance rules can affect facilities that begin construction after stated dates. Buyers typically request FEOC representations, registration numbers and project evidence as part of §48E diligence. Nothing here restates every statutory test.
Rates in brief (same for qualifying technologies)
Per the IRS §48E page: base credit 6% of qualified investment; up to 30% when prevailing wage and apprenticeship rules are met (with the usual small-facility / beginning-of-construction exceptions in the statute); plus possible 10-percentage-point bonuses for domestic content and for energy community location. Transferability under §6418 remains available for eligible taxpayers. See bonus credit overview and §6418 transferability.
What this means if you are buying credits
- Ask which technology generated the credit and which Code section (§48E vs legacy §48 vs a production credit).
- For wind or solar, verify beginning-of-construction or placed-in-service evidence against the OBBBA deadlines.
- For storage, geothermal, hydro, nuclear and other non-wind/non-solar inventory, still verify emissions, registration, FEOC and recapture allocation—the technology label is not a diligence waiver.
- Price and indemnity terms follow the credit’s risk profile; storage and wind/solar pipelines can differ. Compare all-in cost per dollar of credit.
Educational information only, not tax, legal or investment advice, and no outcome is promised. Rules and figures were checked against the cited sources on November 6, 2026; they change, so confirm with your CPA and counsel before acting. Veritas does not offer or solicit investments. See our disclaimer.
Frequently asked questions
Is §48E only for solar projects?
No. §48E is technology-neutral. IRS and Treasury materials describe eligibility for zero-GHG electricity facilities and for energy storage technology. Pub. 6045 examples include wind, solar, hydropower, storage, marine and hydrokinetic, nuclear, geothermal and certain waste energy recovery property.
Does energy storage qualify for §48E without an attached solar farm?
Yes. The statute provides a credit for energy storage technology separately from a qualified facility. Buyers still need registration, transfer documentation and diligence. See our energy storage buyer guide.
Do wind and solar still qualify after the One Big Beautiful Bill Act?
They can, but only within the OBBBA timing rules: generally construction beginning by July 4, 2026, or placed in service by December 31, 2027. Other technologies follow different phase-out timing. See our solar and wind deadlines page and OBBBA summary.
Are fuel cells automatically eligible for §48E?
Not automatically. Pub. 6045 lists qualified fuel cell property among legacy §48 examples, not among the §48E example list. Ask which Code section applies and whether the facility meets §48E emissions and placed-in-service rules.
Can §48E credits from non-solar projects be transferred under §6418?
Yes, when the credit is an eligible §48E credit and the parties meet §6418 rules (unrelated parties, cash, registration, transfer election statement). Technology type does not by itself remove transferability.
- IRS: Clean Electricity Investment Credit (§48E)
- IRS Publication 6045, Investment Tax Credits for tax-exempt and governmental entities (examples under §§48 and 48E)
- Treasury: Final rules for technology-neutral clean electricity credits (§§45Y and 48E) (press release)
- Federal Register: Section 45Y Clean Electricity Production Credit and Section 48E Clean Electricity Investment Credit (Jan. 15, 2025)
- 26 U.S.C. §48E, Clean electricity investment credit (Office of the Law Revision Counsel)
- Public Law 119-21 (H.R. 1, One Big Beautiful Bill Act), Congress.gov
- IRS Notice 2025-42, Beginning of Construction for §§45Y and 48E
- 26 U.S.C. §6418, Transfer of certain credits (Cornell LII)