Meeting the Moment: The Compliance Challenge Shaping Clean Energy

Realizse Insight Series, Issue 2 of 7

The Stakes Couldn’t Be Higher

Developers are racing to safe harbor clean energy projects under the IRA before deadlines hit. But behind the scenes, the One Big Beautiful Bill Act (OB3) is quietly rewriting the rulebook on how credits are validated—and the burden falls squarely on the shoulders of developers.

If you’re a developer, it’s not just about starting your project on time anymore. It’s about whether you can prove, with immutable documentation, that you met every requirement from day one through final credit monetization. If not, the IRS can claw back your credits—years later.

The IRS Is Watching, and OB3 Is the Playbook

The OB3, reinforced by the July 7, 2025 Executive Order, brings Uniform Guidance enforcement to tax credit programs—including ITC, PTC, 179D, 45Q, 45X, 48C, and 48E. For developers, this means:

• Site control and safe harbor events must be verifiable and time-stamped

• Wage, labor, apprenticeship, and domestic content compliance must be substantiated

• Internal controls must be auditable and retained for 6–10 years

• Any weak links in documentation can trigger full IRS recapture or investor litigation

Worst of all, the IRS will look to the developer first when something goes wrong.

The Hidden Traps for Developers

Developers Are Bearing the Burden

While other stakeholders (buyers, insurers, investors) have exposure, developers carry the operational compliance burden. That means project-level failures come back to your desk—even years later.

What Developers Must Now Deliver:

• Proof of compliance from day one, not just legal memos after the fact

• Timestamped project data: wage records, ownership transfers, product origin

• Internal controls documentation for all vendors and subs

• Audit-ready lifecycle documentation that persists through project transfer

If you don’t have these, the risk doesn’t just sit with the buyer. You’re still liable.

Safe Harbor ≠ Safe

Too many developers assume that buying safe-harbored equipment or beginning construction is enough. It’s not. The IRS has made clear that documentation, not intent, will be the test.

“Eligibility under IRA safe harbor rules will be subject to audit and documentation review.”
— IRS Notice, 2025

Even if you meet the threshold, if you can’t prove it, your tax benefits are at risk.

The Developer’s Dilemma

You don’t have the time, staff, or system to build a compliance fortress. And legal memos aren’t going to save you in an IRS audit. What you need is a system and infrastructure to keep track of your compliance process and data:

• A Digital Project Passport that locks in project data from day one

• Automated validation of wage, labor, domestic content, and safe harbor

• An immutable, tamper-proof chain of custody

• Integration across partners: OEMs, financiers, and insurers

Bottom Line: If You Can’t Prove It, You Don’t Own It

For developers, OB3 means that documentation is no longer a back-office task—it’s a survival strategy. And the risk isn’t theoretical. The Treasury has already committed to increasing enforcement, and buyers and insurers are starting to demand verified data.

Without a trusted compliance record, your project might never get funded—or worse, clawed back after transfer.

Coming Next

Issue 3: OEMs & Suppliers – How to Avoid FEOC Triggers and Trace Product Origin Across Complex Global Supply Chains

About Realizse:

Realizse delivers the trusted compliance and product traceability infrastructure clean energy finance now demands. Our flagship solution, the Realizse Passport, transforms fragmented, unverifiable records into a unified, tamper-proof, cryptographically verifiable system of record trusted by all stakeholders.

By providing audit-ready compliance and product traceability data, Realizse unlocks liquidity, mitigates recapture risk, lowers insurance premiums, and reduces audit cost and response time — enabling faster financing and stronger ROI across the clean energy lifecycle.