Overview
- Notice 2026-15 sets a Material Assistance Cost Ratio framework to determine eligibility for Sections 45Y, 48E and 45X.
- For 2026 starts, minimum non-PFE content is 40% for qualified facilities, 55% for energy storage and 50% for eligible components sold in 2026.
- The guidance provides three safe harbors: IRS identification tables that exclude unlisted items, fixed assigned cost percentages and supplier certification affidavits.
- Calculation rules exclude non-manufactured steel or iron from total direct costs, require separate treatment of qualified interconnection property and apply a six-year assessment window for MACR errors.
- The interim rules may be used for projects beginning after December 31, 2025, with proposed regulations forthcoming and comments due March 30, as industry praises clarity yet flags unresolved PFE identification challenges and likely conservative financing.