In the year since the signing of the GOP’s One Big Beautiful Bill into law, many tax credit marketplaces have dropped out of the game.
LevelTen, for example, wound down its marketplace to focus on other areas of its business, cutting a third of its staff just a month after the bill’s passage. Atheva quietly wound down its work entirely. And in late 2025, Evergrow shut down operations and returned to investors what remained of the $14 million it had raised through venture capital.
But the transferability market kept growing all the same. It grew from $28 billion in 2024 to $42 billion in 2025, according to data by clean energy financing platform Crux, and is expected to keep it up in 2026.
That’s despite the wait-and-see-approach many tax credit buyers adopted in the months before the OBBB, when it was unclear whether the transferability clause would survive. And despite policy changes in the bill that temporarily reduced some companies’ tax liability. Both factors are believed to have briefly put a dent in buyers’ appetite for the credits.
As a result, the last year has seen a split in the market, which was created almost overnight when the 2022 passage of the Inflation Reduction Act made it possible for manufacturers and developers of a wide range of clean energy projects to transfer the tax credits, leading to a new way to finance projects. On one side, there’s been growth, bolstered by the renewed certainty. But on the other, there was turbulence; the OBBB seemed to hasten the market’s maturity, with the big players able to withstand the changes, and the smaller ones being more prone to shut down or pivot.
A higher level of diligence
A large reason for the market’s bifurcation is the bill’s introduction of “foreign entity of concern” rules, which tie a project’s tax credit eligibility to whether or not it’s connected to a huge range of companies with both direct and indirect links to China, North Korea, and Iran. Their introduction complicates tax credit trading.
But also, as Andy Moon, CEO and founder of Reunion Infrastructure, one of the largest tax credit marketplaces, explained, “Treasury has not yet clarified large chunks of what it means to be compliant with the FEOC, and so, as a result, insurers are not willing to insure those risks.”
Hans Royal, who leads the North American business development and tax credit arm of Schneider Electric’s renewable energy and carbon advisory practice, said FEOC clarity is an additional “piece of the puzzle” buyers want to solve before acquiring credits. If an entity were to be deemed non-FEOC compliant after it sold its tax credits, he explained, “the buyer of that tax credit would have taxes owed and potentially penalties.”
“A much higher level of diligence and understanding of the supply chain is important to decide whether or not it’s a solid tax credit or if there’s a FEOC concern,” Royal added.
As a consequence, buyers have become pickier.
They either opt for credits from projects that started construction before the end of 2024, and are therefore not subject to FEOC requirements, or pay a lot of attention to the seller’s profile. “Who the seller is is more important to them now than it was before,” Moon told Latitude Media , noting that buyers tend to opt for sellers with high investment grades and strong balance sheets. “There’s a flight to conservatism.”
This is not much of a problem for large corporations, with tax liabilities that justify purchasing big tax credits, and the resources to pay lawyers and advisors to do their diligence. But, as Timothy Doran, who advises tax credit buyers for advisory firm Renewable Credit Management, explains, it might be for small businesses.
“There was already a point upon which the transactional costs make it difficult to access the markets,” he said, but now “there are additional layers of complexity, so that plays into the transactional cost piece of this.”
“I don’t know that all small buyers are precluded from the markets, but in certain circumstances, certain credits might be more difficult for them to access,” he added.
These were precisely the kind of buyers that many shuttered marketplaces were built to serve. Liz Pearce is the chief revenue officer at Ever.green, a marketplace for both high-impact renewable energy credits and tax credits.
“For smaller buyers where the risk-reward calculation is less clear-cut, there’s been a chill on the market,” Pearce said, noting that there’s less liquidity in the sub-$10 million credit amount for transferability. “That’s an amount of tax relief that is not going to get larger corporations excited.”
Ever.green itself is still executing tax credit transactions for its customers, but its main focus is elsewhere. “The outcomes are less predictable, and our response to that has been to refocus our efforts on our other primary offering, which is our high-impact REC offering,” Pearce said.
A project financing market
Alfred Johnson is the co-founder and CEO of Crux, which runs a tax credit marketplace. He says that this need for high levels of due diligence, given that the buyer is subject to some of the risks of project performance, is part of what has prevented tax credits from becoming fully commoditized.
“There was legitimate uncertainty at the beginning of that market, whether the transferable credits would trade more like a commodity, and we would move in the direction of standardization and very rapid deals, or whether the market would look more like project financing,” Johnson said.
In a hypothetical market where firms packaged and guaranteed tax credits, absorbing the underlying project risk on behalf of buyers, tax credits would probably trade more like a commodity. That’s what banks do when they bundle mortgages into guaranteed securities. But for now that isn’t happening for tax credits. “In the absence of that, when actual risk needs to be evaluated by the buyers, it trades more like a project financing market,” Johnson said.
The understanding of credits as a project finance category, rather than an easily tradable commodity, may have been accelerated by the added complexity of FEOC. But in a way, it was embedded in the market from the start. Because assets are heterogeneous, so are credits. “I don’t view this as a commoditized space at all,” Doran said. “Every single project is unique, every single seller is unique, and every buyer has unique preferences.”
As Pearce explains, many of the tax credit marketplaces that “swarmed” the space right after the IRA had started facing the complexity well before the OBBB policy changes. “There was quite a frenzy at the beginning, and people who had never played in this space saw a lot of opportunity,” she said. “Even before the OBBB, companies that were new to this space were a little surprised by the work it took to get these transactions done, and all the rocks they had to turn over to see where the risk was.”
Moon agreed, noting that certain newcomers struggled by the necessity of bespoke transactions. “There were some very tech-oriented platforms that we’re trying to be more like a software platform to match products and sellers, and many of them have gone out of business,” he added.
Companies like Reunion and Crux, which built their businesses on direct client relationships, hands-on diligence, and large deals, have fared well despite the new challenges.
Johnson, for example, took the emergence of the transferable tax credit market as “the initial impetus” to launch Crux. But the company had always planned to help developers raise all layers of the capital stack. “We work with developers and sponsors to identify their capital needs across the wide range of capital products that they will need to raise in order to build the project,” Johnson said. “A developer will typically raise five to seven kinds of capital in building a project: development capital, construction loans, bridge loans, tax credit sales, tax equity, term loans.”
Crux also launched a tax equity strategy about six months ago, closing around $800 million in deals, and started co-investing alongside other institutional investors. In May, it raised $500 million in debt from Nuveen Energy Infrastructure Credit, which it will use to finance its tax-driven investments.
What about wind and solar credits?
OBBB also made the market more selective. That’s particularly true for wind and solar developers counting on selling credits to finance their projects: in addition to introducing FEOC requirements, the new law accelerated the sunsetting of wind and solar tax credits, so that projects coming into service after 2030 will no longer be eligible.
Already, marketplaces are noticing that buyers are becoming cautious about wind and solar credits, spooked by the administration’s hostility toward renewables and what it might mean for project performance down the line. “We have heard from some folks that they have concerns around what the future looks like when you have some uncertainty from the political landscape on how these credits will continue to be treated,” Doran said.
Buyers have plenty of other categories of tax credits to choose from — including the increasingly popular credits from energy storage and clean fuels — so this is not a major issue. But it’s hard on smaller wind and solar developers, who lack the balance sheet and legal resources to weather the uncertainty, Pearce said. Tax credit buyers were previously an important part of their capital stack.
Some projects have been canceled. Others have had to rely on alternative sources of financing, such as forward REC contracts, which is one reason why Ever.green has refocused most of its resources there.
For those projects that do get built, absorbing the financing gap left by expiring tax credits will likely mean higher power purchase agreement prices.
LevelTen, which continued operating as a PPA marketplace after shuttering its tax credit division, recently found that median PPA prices could jump by 40%–50% across most markets, and by as much as 120% in some regions, once wind and solar tax credits are no longer available. Sarah Wolf, director of North American transactions at LevelTen, told Latitude Media that, in some cases, PPA prices could jump from $55 per megawatt-hour to $121.
“After 2030… PPA prices could overheat, so buyers that are looking into what could be as much as 120% price increase are now thinking that they need to act now,” she said. “Once these tax credit projects are gone, they’re gone forever.”
