Recent revisions by the United States Department of the Treasury regarding eligibility criteria for solar energy tax credits have prompted several developers to adopt solutions from GameChange Balance of System (BOS). By eliminating the 5% spending threshold and now requiring proof of “physical work” on-site, the updated rules demand new operational compliance. This regulatory shift has led industry players to secure their projects through tangible components such as transformers.
Custom transformers ensure tax-compliant project start
GameChange BOS enabled 76 solar projects totalling more than 380 MW of installed capacity to be considered “commenced” under the new rules. Through the manufacture and installation of custom-built transformers, these projects qualify for tax safe harbour, preserving access to the 30% tax credit even when permits are delayed. Transformers, essential components in solar systems, are designed uniquely for each project, thereby satisfying the physical work requirement.
Extended compliance window through 2026
Projects containing equipment from Foreign Entity of Concern (FEOC) manufacturers must begin physical work before the end of the year. For all other installations, a grace period is in place until July 4, 2026. This framework introduces uncertainty for developers awaiting utility interconnections or local construction approvals. GameChange BOS’s strategy allows these projects to retain financial viability despite tight regulatory timelines.
Expanded project processing capacity
The company has assembled a team dedicated to documenting and certifying work for Internal Revenue Service (IRS) compliance. It plans to secure an additional 250 projects by year-end and has announced processing capacity for up to 600 projects in 2026. This logistical capability is designed to support growing demand for early regulatory alignment in a sector increasingly constrained by execution deadlines.
“New start-of-work requirements introduce significant uncertainty around financial predictability,” said Phil Vyhanek, President and Chief Operating Officer of GameChange BOS. “Having a BOS provider that manufactures customised solutions enables developers to preserve tax eligibility while advancing their projects operationally.”
