By: Ken Johnston, VP of Sales
The clean energy finance market is not short on capital, projects or long-term confidence. But at Infocast’s 2026 Tax Credits & Transferability conference, one message came through clearly: The path to financing is becoming more exacting, documentation-driven and dependent on risk mitigation than ever before.
Across conversations on tax-credit transferability, FEOC compliance, insurance, 48E and 45X, speakers consistently returned to a common theme, which was that buyers, investors and insurers want clean, financeable transactions — and they are increasingly scrutinizing supply chains as part of that equation.
For domestic solar manufacturers, that shift matters. The companies that can deliver transparent ownership, traceable supply chains and lower-risk procurement pathways are likely to become increasingly valuable partners as the market adapts.
FEOC readiness is becoming a market requirement
Discussions of FEOC compliance dominated the conference. Speakers repeatedly emphasized that the industry expects these requirements to become more consequential over time, with ownership, effective control and material assistance emerging as central diligence questions.
The practical takeaway was blunt: Developers cannot afford to remain intentionally blind to supply,chain risk. The market is moving toward a “reason to know” standard in which counterparties are expected to understand, pressure-test and document the sources of potential FEOC exposure.
That means:
- Knowing the supply chain in detail
- Building procurement controls and contractual leverage
- Using assurance and audit tools where appropriate
- Preparing documentation well before financing or transfer transactions are underway
For manufacturers, this creates a clear strategic opportunity. FEOC readiness is becoming a commercial differentiator. Developers and financiers are actively looking for counterparties that can help reduce uncertainty before it reaches the deal stage.
48E uncertainty is slowing parts of the market
One of the most consistent observations at the conference was that 2026 Section 48E transactions remain difficult to advance while key FEOC questions remain unresolved.
Speakers noted that many grandfathered Section 48 projects remain available, which gives investors less incentive to take on uncertain 48E risk today. The result is a pause in portions of the market as investors, insurers and developers wait for clearer Treasury guidance. Conference participants identified Q3 or early Q4 2026 as a potentially important period for additional clarity, though the market is already behaving as if more rigorous compliance expectations are coming.
This has a direct implication for equipment procurement. The more uncertainty surrounding project-level tax-credit eligibility, the more valuable it becomes to minimize avoidable risk elsewhere in the transaction. A transparent, domestic, well-documented supply chain can help developers tell a cleaner story to capital providers.
Insurance is moving toward the center of tax-credit monetization
Insurance surfaced in nearly every major discussion. FEOC insurance, tax insurance and coverage for fair market value (FMV) step-up structures are increasingly viewed as important tools for allocating risk and helping transactions proceed.
But the market is still evolving. Speakers emphasized that insurance structures should not be finalized too early, especially before the tax-credit buyer is known. Different buyers may require different coverage terms, and insurance procured too soon can create mismatches, rework and added cost.
Several broader themes stood out:
- FEOC insurance is becoming expected, if not required, in many transactions.
- Tax insurance is frequently used in FMV step-up structures.
- Buyers increasingly prefer structures where insurance absorbs first-loss risk.
- More sophisticated policies, including “double-trigger” approaches, are entering the market.
The larger signal is that risk mitigation is now a core component of transaction design, and insurance is only one part of that story. The more a project team can reduce uncertainty through diligence, documentation and procurement choices, the stronger its financing posture becomes.
45X credits are viewed as cleaner and more financeable
Compared with the uncertainty surrounding 48E, 45X manufacturing credits were generally viewed more favorably by conference participants. Speakers described them as cleaner, easier to perform due diligence on and lower in recapture risk, making them more financeable in the current environment.
That does not mean scrutiny disappears. Buyers still prefer:
- Investment-grade or highly credible counterparties
- Strong documentation
- Clear compliance pathways
- Insurance where appropriate
But the broader sentiment was that 45X credits present a more straightforward opportunity than structures where evolving FEOC interpretations could affect project economics.
For U.S. solar cell manufacturing, this is significant. As domestic production scales, the combination of manufacturing credits, traceable supply chains and domestic industrial capacity may become an increasingly important pillar of clean energy finance.
FMV step-up structures are expanding — but complexity matters
FMV step-up structures remain a major area of market interest, particularly as developers and investors look to optimize monetization. Infocast speakers discussed:
- Standard FMV step-ups in the 15%–20% range
- Preferred equity structures that may support 25%–30% step-ups
However, participants also stressed that these structures are not universally practical. Insurance is often required, legal and accounting complexity remains high, and transaction costs tend to favor larger projects. A notable conference observation was that projects below roughly $10 million may struggle to justify the additional complexity and expense.
The broader takeaway? The market is willing to pursue sophisticated financial structures, but only when the underlying transaction is clean enough to support them.
Buyers want simplicity, strong counterparties and no surprises
Corporate buyers delivered one of the clearest messages of the summit: They want benefits without unnecessary risk.
Reputation, execution and documentation matter. Surprises can derail a deal quickly. Speakers repeatedly emphasized the value of a “simple and clean story” — a transaction that is easy to perform due diligence o, easy to explain internally and free of avoidable uncertainty.
That mindset affects not only tax-credit structures, but also vendor selection and supply chain strategy. In a market where buyers are already managing new compliance obligations, they are less likely to tolerate ambiguity from counterparties that cannot clearly demonstrate ownership transparency, traceability or readiness for diligence.
The long-term outlook remains constructive
Despite all the near-term friction, the tone at Infocast was not pessimistic. Speakers remained confident in the long-term fundamentals of the market:
- There is still capital seeking clean-energy opportunities.
- There is still a substantial pipeline of projects.
- Power demand continues to rise.
- Storage growth expectations remain strong.
- Distributed generation, C&I and utility-scale markets remain active.
- Domestic manufacturing capacity continues to matter.
The industry appears to expect adaptation, not collapse.
That distinction is important. The market is not retreating from clean-energy finance—it is raising the bar for what qualifies as financeable.
What this means for domestic solar manufacturing
For U.S. solar manufacturers, Infocast’s message was especially relevant. Domestic manufacturing is gaining importance not only as an industrial policy goal, but as a financeability tool. Buyers and investors are placing more value on supply chains that are controllable, transparent and easier to perform due diligence on.
That is particularly meaningful as developers navigate FEOC uncertainty and look for ways to reduce exposure before projects reach underwriting. Manufacturers will be better positioned to serve a market that increasingly rewards certainty if they offer:
- Clear ownership structures
- Transparent documentation
- Traceable, lower-risk supply chains
- Strong compliance readiness
- Repeatable diligence support
The takeaway from Infocast was clear: In 2026, financeability is about whether every component of the transaction — including the supply chain — can withstand scrutiny.
The manufacturers that help customers reduce uncertainty will not simply be suppliers — they will become strategic partners in getting projects financed and built.
Building for the market that is emerging
At ES Foundry, we believe the next phase of U.S. solar manufacturing will be defined not only by domestic capacity, but by bankability, transparency and execution readiness. As FEOC diligence becomes more rigorous and financing decisions become more documentation-driven, developers and module manufacturers will need supply-chain partners that can help them move with greater confidence.
That is why ES Foundry has prioritized a FEOC-free, U.S.-based manufacturing platform from inception — designed to support traceability, reduce compliance uncertainty and provide customers with a more financeable path forward.
As the market continues to evolve, we welcome conversations with developers, module manufacturers and financing partners looking to build more resilient, diligence-ready U.S. solar supply chains.