This was authored for Banyan Infrastructure by Rob Glen, an energy markets and infrastructure strategist with more than two decades of experience advising technology companies, investors, and infrastructure developers on market strategy, commercialization, and strategic partnerships. Previously, he helped build and scale BloombergNEF's energy transition intelligence business and held senior leadership roles at 451 Research, bringing deep industry expertise to the convergence of AI, grid modernization, and the global energy transition.
As the One Big Beautiful Bill Act (OBBBA) made its way through Congress last year, there was understandable concern that its curbs on wind and solar subsidies might slow clean energy finance to a crawl. The final version accelerated the phase-out of the Section 45Y and 48E credits for wind and solar projects, imposed Foreign Entity of Concern (FEOC) rules, and left developers waiting on Treasury guidance for how to even calculate compliance. While certainly not the worst-case scenario feared at the outset of the legislative process, many still expected a chilling effect on project financing in the renewable sector.
More than a year since the legislation was signed, tax credit volumes have thus far proved the doomsaying premature. Total tax credit monetization is on pace to approach $70 billion by the end of 2026, up roughly 11% year-over-year, and the flow of capital to clean energy across power, manufacturing, and clean fuels is tracking toward more than $143 billion, a 19% increase over 2025. The market for credits didn't shrink under OBBBA. Thanks in part to growing demand for power and scaled-up 45X and 45Z volumes from manufacturers' investment and renewable fuel production, it expanded; part of that unexpected traction stems from credit transferability.
Transfers are absorbing the shock
Under the Inflation Reduction Act of 2022, a developer can sell a clean energy tax credit to a corporate buyer rather than (or alongside) structuring a traditional tax equity partnership. Transfer volume grew from $32 billion in 2024 to $42 billion in 2025, a 48% year-over-year increase. Crux — the marketplace and data provider that tracks the bulk of transfer activity — now projects $47.5–49 billion for the full year, up as much as 18% from 2025. That's a market absorbing a genuine policy shock within two quarters and coming out the other side larger than before.
A market growing in two different directions at once
The more interesting story isn't just that transfers grew; it's how. Two distinct dynamics are driving that growth, and they're pulling in different directions.
On the dollar side, growth is concentrated in large, complex transactions. Nearly half of the credit volume purchased in 2025 covered other tax years, including close to $9 billion in long-dated production tax credit (PTC) strips. The deals involve very large, multi-year commitments typically negotiated by banks and other sophisticated corporate buyers and large sellers and move enormous dollar volume.
On the participation side, by contrast, the market is broadening. Roughly 243 Fortune 1000 companies — nearly a quarter of the index — were active tax credit buyers through the third quarter of 2025, a nearly 60% year-over-year increase in the number of member corporations buying credits. This figure doesn’t include smaller taxpayers that have joined the supply side as their accountants and other financial advisers have become more comfortable using clean energy credits to offset taxable income. Crux's own market guidance is explicit about why: transferability exists precisely because traditional tax equity's scale and structuring requirements historically shut out smaller or newer developers on the sell-side and corporations and high-net-worth individuals with less predictable incomes on the buy-side. The transfer market gives them a simpler way in. As more of those developers and buyers enter, the number of individual deals in the market grows even where dollar volume doesn't grow at the same clip. A small handful of nine-figure PTC strips can dwarf hundreds of smaller transactions in dollar terms while the transaction count tells the opposite story.
The upshot: the market's dollar growth and its unit growth are being driven by different populations of participants, and the smaller end of that population — the C&I solar deal, the single-project ITC transfer, the first-time seller — is where the count is actually expanding.
Small deals don't get a smaller diligence burden
This is where the mechanics of a tax credit transfer matter, because they don't scale down with deal size.
A transfer isn't a simple bill of sale. Proceeds from a credit sale are tax-exempt cash to both the seller and the buyer. There’s no above-the-line impact on either side's taxable income, which is exactly why the cash has to be tracked as its own distinct line rather than folded into revenue. And that cash is never a dollar-for-dollar swap. Credits typically trade at a discount to par, commonly in the 85–95 cent range, sometimes less for higher risk technologies and weaker or smaller projects. Each transaction requires computing proceeds as credits sold times price per credit, with the credit quantity itself often still moving. ITCs are calculated as a percentage of build cost or fair market value through commercial operation, PTCs as a percentage of actualized generation and sales.
None of that complexity is a function of deal size. A $2 million single-project ITC transfer requires almost as much work as a $200 million PTC strip: verifying the credit amount, pricing the transfer, tracking the buyer relationship, screening for Prohibited Foreign Entity exposure, negotiating the tax credit transfer agreement, and reconciling projected proceeds against what actually clears. The $200 million deal can justify a bespoke team of advisors underwriting the diligence and transaction cost across a large transaction. The $2 million deal, run by a smaller developer who may be transacting for the first time, cannot. That developer is exactly the transfer market participant that Crux's data shows is growing the fastest.
Why the software layer matters more, not less
This is the gap the current generation of finance and compliance software is built to close. Tools that automate PFE screening against cap tables and supply contracts, price transfers using market-wide bid data rather than one-off negotiation, and track variance between projected and actualized credit quantities effectively substitute software for the fixed cost of diligence that used to require a specialized team on every deal, at every size.
Purpose-built FEOC and prevailing-wage compliance tools automate the legal review — cap tables, supply contracts, watchlist screening — that used to be manual and expensive regardless of transaction size. And project finance platforms like Banyan Infrastructure are extending that logic across the full deal lifecycle, applying the same AI-driven ingestion and scoring to legal, financial, and covenant data that a fixed diligence team once tracked by hand.
The pattern across all of these categories is the same: software absorbs a cost that doesn't scale down, which is exactly what makes it valuable to a market whose unit growth is coming from participants who can least afford to pay that cost themselves.
Where this goes next
If the transfer market keeps broadening the way 2025 and 2026 suggest — namely, more buyers, more first-time sellers, more small deals alongside a handful of enormous ones — the tools built for one narrow purpose (e.g., pricing, Prohibited Foreign Entity screening, proceeds tracking) are likely to keep converging into single platforms that can serve a deal at any size without changing the underlying workflow. The clean energy sector spent the last two years absorbing a policy shock that was supposed to shrink the market. Instead, it grew, fragmented into more and smaller pieces, and built exactly the kind of standardized, repeatable, data-intensive problem that software is positioned to solve.
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