The GOP’s law contains a rapid phase-out of the investment tax credit (ITC) and production tax credit (PTC) for wind and solar projects. To claim the credit, projects must commence construction within 12 months following the enactment of the OBBBA (i.e., before July 4, 2026) or they must be placed in service before January 1, 2028. This applies to wind and solar only. The law also introduces Foreign Entity of Concern (FEOC)/Prohibited Foreign Entities (PFE) restrictions that kick in beginning in 2026, creating cumbersome restrictions and rendering the tax credit effectively unworkable. More specifically, solar and wind projects can only claim credits in the following scenarios:  

• Wind and solar projects that commence construction before December 31, 2025, will get a four-year window to be placed in service. These projects will not have to comply with Foreign Entity of Concern (FEOC) Material Assistance restrictions, but they do have to comply with the FEOC/PFE entity level and payment restrictions to claim the credit in 2026. 
• Wind and solar projects beginning construction between January 1, 2026, and July 4, 2026, will also get a four-year window to be placed in service to claim the credit. These projects, however, must comply with all FEOC/PFE restrictions.
• Projects that commence construction after July 4, 2026, must be placed in service by December 31, 2027, to claim the credit. These projects also must comply with all FEOC/PFE restrictions.

ITC/PTC credits remain for geothermal, hydropower, nuclear, and energy storage, although FEOC/PFE restrictions apply.

An earlier version of the Senate bill was much more punitive to clean energy. It applied a placed-in-service standard on an even shorter timeline than the House, as well as FEOC/PFE restrictions. It also levied an extremely punitive new tax on solar and wind.

The new law will rapidly phase out the credits and crush the booming manufacturing and clean energy industries in communities across the United States. Repealing the clean energy tax credits would worsen the affordability crisis, raise energy bills, harm grid reliability, kill jobs, and inflame the climate crisis.

• Skyrocketing energy prices: The GOP’s repeal of the clean energy tax credits would raise American household energy bills. It could increase annual energy bills up to $140-$220 per household across the country in 2040, and over $500 per year in some states. 
• Kill good-paying jobs: Full repeal of the 45Y and 48E clean energy tax credits alone would result in roughly 100,000 fewer full-time jobs across the country by 2040. (For context, the final OBBBA is projected to result in a loss of roughly 900,000 jobs in 2032.) 
• Harm grid reliability: These tax credits are enhancing grid reliability in the face of increased electricity demand and extreme weather. Clean energy is the fastest, cheapest way to add new power to the grid. In fact, clean energy accounted for 93 percent of the new energy capacity added to the U.S. grid last year.
• These changes jeopardize billions of dollars of existing investments, including any project underway now that won’t be fully operational by 2027. By stifling the booming solar and wind industries, Republicans are ensuring that our international competitors take the lead on clean energy development, setting back American energy dominance.
• Slashing the clean energy tax credits would worsen the climate crisis. Saving the 45Y and 48E tax credits would cut climate pollution by 300 to 400 million tons compared to no tax credits in 2035. That’s 29-46 percent lower than a scenario without clean energy tax credits. After a year marked by devastating, billion-dollar climate disasters, floods, and fires, it’s more important than ever that we address climate head-on.

The law ends EV tax credits for new EVs (30D) and used EVs (25E), commercial clean vehicles (45W), and fueling infrastructure (30C) as of September 30, 2025.

The final OBBBA eliminates credits faster than the House bill proposal. 

• In the final law, the used EV (25E) tax credit is eliminated by September 30, 2025. In the House version, it was the end of 2025. 
• The new EV (30D) tax credit is eliminated by September 30, 2025. In the previous Senate version, it was within 90 days of passage. In the House version, the credit would terminate at the end of 2025. In the House bill, drivers can get a tax credit for qualified vehicles from manufacturers who have not yet hit the 200,000 EV cap through December 31, 2026. There is no such provision in the final law.
• The new clean commercial vehicle (45W) tax credit is eliminated by September 30, 2025. In the House bill, it was the end of 2025. 
• The vehicle charging infrastructure (30C) tax credit is eliminated by June 30, 2026. This stands in contrast to the House bill, which ended the credit at the end of 2025. In the previous Senate bill, the credit was eliminated a year after the bill’s enactment.

Fully repealing the IRA’s EV tax credits will drive a wrecking ball through the American-made EV industry. It will cause major job losses, according to the CEO of the Ford Motor Company, and will benefit China, according to General Motors. For households, new and used electric vehicles would become less financially accessible, meaning consumers would have fewer transportation options.

The GOP’s law retains portions of the 45X credit at full value through 2032; the credit for wind components is terminated after 2027, and most critical minerals incentives are phased out by 2032. FEOC restrictions still apply to the 45X credit. In a harmful twist, the law delivers a handout to the coal industry by defining metallurgical coal used for steel production as a critical mineral under the credit through 2029. 

The 48C tax credit is amended so that any rescinded credits from projects that aren’t completed within two years cannot be reallocated.

The final law is substantially similar to the previous version, with the new addition of the metallurgical coal qualification.

The 45X Advanced Energy Manufacturing Credit sparked a renaissance in U.S. manufacturing, especially for electric vehicles, advanced batteries, and solar energy and their supply chains. The credits have helped incentivize over $200 billion in new investment in the U.S. and positioned the U.S. to be competitive in critical 21st-century global industries. This incentive has contributed to job and manufacturing growth—most of which is in districts that Republicans represent. 

The law’s amendments to 48C will threaten the certainty of building industrial facilities and the jobs that come with them. It also means the credit will be effectively repealed after two years by not allowing for the recycling of rescinded credits from failed projects to qualified ones.

The GOP’s final law would eliminate the Energy Efficient Home Improvement Credit (25C) effective December 31,  2025. It eliminates the New Energy Efficient Home Credit (45L) after June 30, 2026. The Energy Efficient Commercial Buildings Deduction (179D) is amended so that it does not apply to property whose construction begins after June 30, 2026.

In the final law, the Energy Efficient Home Improvement Credit (25C) is eliminated at the end of 2025. This is the same timeline as the House version. The previous Senate version proposed 180 days after bill enactment. In the final law, the New Energy Efficient Home Credit (45L) is eliminated for homes acquired after June 30, 2026. The House bill eliminated the credit at the end of 2025 unless the home construction begins before May 12, 2025. The House bill did not include the elimination of the Energy Efficient Commercial Buildings Deduction (179D). 

Cutting building energy efficiency credits takes money out of people’s pockets by making home energy upgrades more expensive and raises everyone’s utility bills by reducing efficiency and putting more pressure on the electric grid. Households can currently save $990 per year on utility bills if they utilize the 25C tax credit, and these credits create 240,000 jobs. By effectively terminating the Energy Efficient Home Credit for new buildings, this is a major gut punch to any builders trying to provide new homes to address the housing crisis.

This law eliminates the Residential Clean Energy Credit—which incentivizes homeowners to install solar panels, water heating, fuel cells, wind, geothermal heat pumps, and battery storage facilities—after December 31, 2025. 

The House version is the same, eliminating the credit at the end of 2025. The previous Senate bill eliminated the credit 180 days after the bill’s enactment.

Households will see higher costs for home energy upgrades and lose access to $1,250 in savings per year on utility bills. At the same time, we’ll cut a huge source of new energy capacity just as demand on the grid is increasing, which will raise energy costs for everyone. Plus, cutting the residential clean energy tax credits will kill hundreds of thousands of jobs in the home energy and rooftop solar sector.

The FEOC/PFE restrictions applied across clean energy and manufacturing tax credits are unworkable and, in some cases, extraordinarily punitive for industry. The law establishes a material assistance (supply chain) cost ratio framework—modeled after the existing domestic content bonus—that sets credit-specific eligibility thresholds based on the share of materials used across different technologies. It applies material assistance requirements to all ITC and PTC  projects that commence construction after December 31, 2025. Projects must also pass new foreign “Ownership and Influence"  restrictions beginning in tax year 2026  to claim the credits. The restrictions test for priority ownership or control from a number of “foreign entities of concern” and includes overly punitive measures like issuance of debt and ability to appoint board members as part of its review. Additionally, beginning in tax year 2026, there is a new rule that payments an ITC or PTC taxpayer makes to a specific foreign entity that could give “effective control” of any one of their facilities will disqualify them from the tax credit. This rule is retroactive and is determined based on payments made in the prior tax year, so payments made in 2025 are subject to this rule. Projects could face a full credit recapture if they violate this rule anytime within 10 years of claiming the credit. 

The previous Senate bill FEOC restrictions were similarly unworkable, imposing a material assistance cost ratio framework that applied to solar and wind projects that began construction after June 2025. There was similarly a Prohibited Foreign Entity test tied to foreign ownership and influence. And for solar and wind energy projects, the previous Senate text included an excise tax that was functionally a supply chain penalty, even if after the underlying credits were set to expire. The previous Senate version’s excise tax was equal to the percentage by which a faculty fails the material assistance cost ratio times the facility’s manufactured component cost. The excise tax is not reflected in the final law; however, the FEOC requirements are still burdensome and unworkable. 

FEOC restrictions may make the credits unworkable for most new solar and wind projects—raising energy costs, killing jobs, and undermining U.S. investment and economic competitiveness. Some adjustments were made to the House bill to address industry concerns, but FEOC restrictions will also raise costs and hardship for energy and manufacturing projects. 

The OBBBA repeals Section 134 of the Clean Air Act, in which the GGRF was created. Any unobligated balances are rescinded.

There is no change to the House version.

The GGRF is unlocking a historic wave of public and private investment, delivering local economic development opportunities that would not have materialized without this program, especially in disadvantaged communities. But the Trump administration has already been attacking the GGRF through an illegal funding freeze, and a court battle is currently raging with program awardees, in particular the NCIF and CCIA programs. The GGRF funding has technically been obligated, and only minimal GGRF funds remain unobligated and available for rescission. But this law will harm program implementation and oversight at EPA.

The law rescinds any unobligated funding under the Climate Pollution Reduction Grants (CPRG) for plans and implementation grants.

Same as the previous version.

The CPRG program is a primary vehicle for states to fund their pollution reduction programs. Rescinding unobligated funding for the CPRG program will dramatically harm program implementation at the agency. Many awarded states could have to stall or permanently halt their pollution reduction plans that were intended to create jobs, reduce energy and transportation costs, and mitigate pollution in impacted communities.

The OBBBA rescinds all unobligated funding under Section 60201 of the IRA, which provided funding for highly flexible grants to nonprofit organizations serving disadvantaged communities.

The final law closely mirrors the House version. 

Without EJ Block Grants, there will be less financial support for on-the-ground, community-led organizations that provide life-changing services to households based in disadvantaged communities or living near sacrifice zones. Examples of critical services include community-led pollution monitoring, prevention, and remediation; projects that reduce indoor air pollution; projects to counter health risks from urban heat islands, extreme heat, and wildfires; improved community engagement in public processes; and technical assistance. Much of these funds are unobligated.

The law rescinds all unobligated funding from Section 60113 of the IRA, which provided funding to the EPA for financial and technical assistance for methane monitoring and mitigation. The GOP retains a fee on excessive methane waste, known as the Waste Emissions Charge (WEC), but the language is altered so that the collection of charges is postponed until 2034, as opposed to 2024 under current legislation. This renders the fee largely ineffective for the next decade.

This is similar to previous versions of the text.

By cutting methane pollution and other harmful pollutants, the WEC would have helped prevent asthma attacks and other health-harming impacts. The program would have reduced an extremely harmful greenhouse gas superpollutant. Altering the WEC will disproportionately impact communities of color and disadvantaged communities. The methane fee is also a revenue raiser, so its alteration increases the budget deficit and would necessitate even deeper cuts to other vital programs to comply with the GOP’s self-imposed spending cut targets.

The law has created a new “opt-in fee” mechanism that would allow project sponsors to receive special treatment in the environmental review process. In exchange for a fee of 125 percent of the costs to prepare the environmental document, the project sponsor receives an expedited review.

The previous Senate version had a provision that allowed project sponsors to skirt judicial review for a fee. The parliamentarian found the judicial portion violated the Byrd rule and was therefore struck.

This is a continuation of the “pay-to-play” politics we saw in the GOP’s House version, but this time, the law has attacked the National Environmental Policy Act (NEPA), which provides for environmental reviews of all major government actions.

Scientists and peer-reviewed academics have repeatedly found that there simply is no room for new coal, oil, and gas fields if we want to limit planetary warming to 1.5C. Flying in the face of climate science, the Republicans’ final law recklessly accelerates oil and gas extraction on America’s public lands and waters. The OBBBA sets a floor for the minimum number of onshore and offshore oil and gas sales annually and lowers the barriers to oil and gas leasing, including in the Arctic National Wildlife Refuge, the Gulf of Mexico, and Alaska’s Cook Inlet. This law will reinstate onshore non-competitive leasing processes, lengthen drilling permit terms, and cut royalty rates to 12.5 percent. Each of these provisions lowers the barrier to access for Big Oil to exploit U.S. public lands and waters. The law also includes a massive expansion of coal leasing across federal lands, making at least 4 million acres of public land available for coal leasing. The OBBBA provides significant handouts to Big Coal by reducing the royalty rates for coal extracted on federal land.

Leasing was made competitive so that government agencies could ensure the best and most efficient use of taxpayer dollars and reduce opportunities for corruption. This law opens the door to backroom dealing through expanded non-competitive processes and reduced fees. The OBBBA also encourages gas and oil drilling nationwide, which will increase air pollution, increase greenhouse gas emissions, and hold our national economy back by supporting reliance on non-renewable energy resources. Make no mistake: This is a cheap sell-out of our nation’s precious natural resources, an act of climate arson, and a poisoning of communities—all to facilitate a gargantuan handout to fossil fuel corporations.

The final law repeals and rescinds unobligated funds for transmission facility financing, grants to facilitate the siting of interstate electricity transmission lines, and interregional and offshore wind electricity planning, as well as modeling and analysis. 

Same as the previous version.

Republicans claim to care about energy dominance and cheap energy, but this nonsensical action would sabotage efforts to make our grid more affordable, reliable, resilient, and energy secure.

The GOP’s law effectively ends financing for new clean energy and advanced manufacturing projects under LPO. In a critical change, it amends the 1706 program into a so-called “Energy Dominance Financing” program, which cuts the requirement that projects reduce emissions, adds extra categories for project eligibility, and provides $1 billion in credit subsidy for energy and minerals projects. 

The previous version also rescinded unobligated balances from LPO programs under Sections 1703 and 1706.

Fundamentally altering LPO’s new loan authority is a devastating blow for the U.S., especially amidst rising energy demand and a competitive global race to build and manufacture the energy technologies that will power the 21st century. It will harm American businesses and U.S. technology leadership. Not only that, over the long term, shrinking LPO will cost American taxpayers money, as the successful program has already returned $5 billion in profit to the American taxpayer, via interest on its loans.

Rescinds unobligated balances.

In addition to rescinding unobligated balances, the previous Senate text also repealed the Advanced Industrial Facilities Deployment Program (AIFDP). Only rescinding unobligated balances puts this law in line with the House E&C text, which also rescinded funding but did not repeal it altogether.

Rescinding unobligated balances and eliminating the AIFDP program deal a major blow to U.S. global economic competitiveness as American businesses fight for market share in increasingly decarbonized steel, cement, aluminum, and other heavy industries.