48E and 45Y Tax Credit Compliance: What Developers and IPPs Need to Know

3-3:45 p.m. (ET) | 2-2:45 p.m. (CT) | 12-12:45 p.m. (PT)

Developers and IPPs that began construction on tax credit qualifying projects in 2025 or later are now subject to Section 48E and 45Y requirements for PWA, domestic content and other rules, which are more onerous than what has historically been required. 

Compliance under 48E and 45Y generally operates at the qualified facility level. That means PWA records and domestic content traceability need to be managed facility by facility, not project by project. Additionally, projects beginning construction in 2026 or later are subject to the FEOC MACR Requirement, which also applies on a qualified facility basis. While some requirements can be managed at the project level to comply at the qualified facility level, others must be managed more granularly.

Join Empact Technologies, McGuireWoods and Lockton for a 45-minute panel covering what the law requires, what tax credit insurers expect to see and what compliance looks like in practice on live projects.

What We’ll Cover

• The qualified facility definition under 48E and 45Y, what compliance obligations attach at that level and what limited obligations can continue to be managed at the project level to meet qualified facility-level compliance
• What the One Big Beautiful Bill Act added for the FEOC MACR Requirement and what developers need to do if they were not tracking at the facility level before
• Where 48E and 45Y compliance gaps are creating friction in underwriting right now and what a complete diligence package looks like
• What records need to exist, who owns them and how to get a program right if construction is already underway

Speakers

• Alan Cordova | VP Strategy and Partnership, Empact Technologies
• Aaron Mitchell | Associate, Tax & Employee Benefits, McGuireWoods
• Dan Berger | Head of Tax Insurance, Lockton

CLE credit applications will be made on behalf of attendees.

For more information, contact Beth Winstead at [email protected].

Our programs are intended for the benefit of our clients and contacts and we reserve the right to refuse any registration at our sole discretion. © 2026 McGuireWoods LLP. All rights reserved.