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The state of clean energy finance in 2025: Q&A with Crux's Katie Bays

February 24, 2026

The last year was marked by complexity for clean energy project finance. Capital remained available across a diverse set of technologies, new financing structures continued to develop, total lending reached a record $120 billion, and total tax credit monetization across tax equity, preferred equity, and transfers grew to $63 billion. At the same time, economics tightened for some technologies, tax credit pricing softened in certain segments, and the market continued to adapt to a shifting policy environment.

Today, Crux published its semi-annual market intelligence report to provide a comprehensive look at how clean energy project finance fared in 2025. Drawing on Crux's proprietary deal-level transaction data as well as public sources, the report examines the debt, tax credit transfer, and tax equity markets in 2025 and offers an outlook for 2026.

Crux Director of Research Katie Bays led the research effort. She recently sat down with Crux's marketing team to discuss the report's key findings and what they mean for developers, lenders, and tax credit buyers heading into 2026. Their conversation has been lightly edited for clarity and length.

Download the report for the complete analysis.

Crux: Before we dive into the data, could you tell us a bit about what went into creating this year's market intelligence report?

Katie Bays: We knew that the calendar year 2025 had been a very dynamic year for most of the clean energy economy. So, when we began to put together our plan for this year's market intelligence report, our objective was to really advance the ball as much as we could across all of the major market segments that Crux serves, from tax credit transfers to debt to tax equity, in order to shed as much light as possible into how the industry coped with such a noisy and exciting year.

Crux: The report describes 2025 as a year defined less by disruption than by differentiation. Can you talk about that distinction and what it means in practice?

KB: Yes. What we generally found across all of our data was that, in many cases, the market remained resilient and achieved ambitious investment milestones, but that this was driven most acutely by companies and projects that have traditionally had the best access to capital. For instance, we saw a very high rate of utility-scale solar installation — falling just behind the 2024 record. And we also saw a record level of energy storage installation. Those are two of the most, at this point, established technologies in the power space.

At the same time, we did see a reduction in aggregate investment in manufacturing and fuels — which were less well-positioned from the point of view of traditional project finance.

Crux: What finding from this research effort surprised you the most?

KB: We were prepared to see a very flat year-over-year figure for total tax credit monetization, and we were genuinely surprised to see that total monetization actually accelerated to $63 billion in 2025, despite everything that was happening in the macro environment. When you pull back the curtain and look at what drove that growth, it was two things: 

First was the significant increase in total tax equity investment, growing to $36 billion in 2025, which in turn was a function of the rising use of hybrid tax equity structures — which I am sure we are going to talk about later. 

Second was growth driven by tax credit buyers who were making a much larger volume of long-term tax credit purchase commitments than we have observed in years past.

Crux: The report showed total lending to clean power, fuels, and manufacturing reached $120 billion last year. What segments drove that continued growth?

KB: One of the key themes that we found in our research was that all of the investment areas linked to the flexibility and liquidity of the tax credit transfer market grew and drove growth across the entire clean energy economy. So, when I say that, what I mean is we saw a record amount of debt capital deployed — we're focused on greenfield project finance debt, which means pre-NTP, construction, and bridge lending. We look at those three sources of project finance investment and we get $120 billion, which is a record. 

What drove that $120 billion investment level was actually bridge lending — we saw about a 9% year-over-year increase in bridge lending. This investment structure is also an area where we've seen a significant amount of innovation. The evolution of traditional tax equity bridge lending has come to accommodate more flexible structures, like preferred equity, so we're seeing bridge lending to preferred equity investments. We also see bridge lending to tax credit transfer commitments that have been negotiated for a future year. In rare cases, a bridge lender will even advance capital to a project that does not yet have a tax credit transfer agreement negotiated, also called an uncommitted bridge loan. 

But across the board, that was the area where we saw the most growth, and I think it's not surprising, given that the market is still evolving and adapting to the kinds of flexible investment structures that are made possible by transferability.

Crux: Can you talk a little bit about the volume and pricing trends in the tax credit transfer market you observed throughout 2025 and what you expect in 2026?

KB: Within specifically the tax credit transfer market, we were open-minded about what we thought aggregate volume might be for 2025. We knew that, in many ways, the market had decelerated in the second half of the year, so we were prepared to see a smaller market in the second half. That’s exactly what happened: the market generally was not as active in the second half. Overall, however, we did see another record level of market activity in 2025. We estimate $42 billion in tax credit transfer volume in 2025, which is up approximately 27% from $32 billion in 2024. That happened because buyers broadened the types of tax credits they were purchasing.

We've historically seen that the majority of deal activity is concentrated on the current tax year. In 2025, what we found was that only about half of deal activity centered around a 2025-vintage tax credit. The other half of the market was a combination of 2024 tax credits, long-term production tax credit (PTC) strip purchases, and forward investment tax credit (ITC) purchases — really, buyers diversifying the vintages that they are interested in purchasing, and incorporating, in many cases, tax credit purchases into long-term planning.

As we look to 2026, I think we do expect to see a significant volume of 2025 tax credits transact within this calendar year. Our expectation is that $8–10 billion will transact. But we are also very interested to see if the buy-side interest in long-term purchases sustains itself through 2026.

Crux: Hybrid tax equity structures now make up a growing portion of the tax equity market. Why have they become a dominant form of tax equity investment?

KB: I think many tax equity investors are finding that the hybrid structure — wherein they are able to transfer a portion of tax credits and retain a portion to satisfy their own tax requirements — is a best-of-both-worlds model. The tax equity partner benefits from faster recycling of capital, they're able to deploy more capital in aggregate, and they do not have to rely on their own tax capacity to limit the amount of their investment. And then, on the other hand, they are able to transfer into a liquid, efficient market to monetize the tax attributes that they can't retain.

So, we've really seen that major tax equity sponsors are pursuing this as their principal investing format. That doesn't mean all tax equity partners will do this; there are many that prefer traditional structures and will continue to offer those as well. But it's very clear that substantial growth is coming from the ability to upsize commitments by structuring them as a hybrid investment.

Crux: PTC strips grew dramatically in 2025, reaching over $9 billion. What's behind this surge in developers electing PTCs over ITCs?

KB: We know that a lot of tax credit buyers do come to the market with a preference for PTCs. PTCs have benefits in that they don't have the same types of tax risks as ITCs do. For instance, recapture and basis considerations are not as pronounced with PTCs for the most part.

The interest in PTC strips specifically, I think, speaks to the desire by many large corporate taxpayers to budget for tax credits as a part of their long-term tax planning and tax strategy. Those commitments we saw are typically 10 years, though they can be shorter. And they are typically for some of the traditional technologies — for instance, wind and a fair number of solar PTC strips. For some tax credit buyers, these long-term commitments are the most economic and practical way to ensure a reliable, annual supply of low-risk tax credits.

Crux: In 2026, tech-neutral tax credits should make up a larger portion of the tax credit supply. What did the market look like for tech-neutral tax credits in 2025, and how does it look moving forward?

KB: It's a complicated question, because the tech-neutral tax credits are not homogenous in terms of their structure and the kinds of diligence that is involved in purchasing one of those tax credits. Tech-neutral tax credits are subject to, broadly, foreign entity of concern (FEOC) risks. Those risks vary based on a variety of factors: whether the tax credit is generated in 2026 or later, whether the project met beginning-of-construction requirements, how they met those requirements, and by when. So, there are a lot of questions within the tech-neutral regime that both investors and tax credit buyers are considering.

All that said, we do see a market for these §48E tax credits generally. There's a modest price discount that we were able to observe in our data — §48E tax credits will generally attract bids at about $0.015 below what the average rate is for a similarly situated legacy §48 tax credit — but the market does exist, and we do expect these tax credits will transact in 2026. Moreover, we expect that the market for §48E will clear, just as it historically has for §48.

Crux: Tax credit–eligibility timelines for solar and wind projects were shortened in the OBBB, and July of this year marks the deadline for their safe harbor. How is this affecting the investment environment for these technologies?

KB: We wanted to understand what that safe-harbor pipeline looked like, so we conducted an analysis to observe the volume of projects that had been announced but had not yet entered service based upon the various safe-harbor milestones — whether December 31, 2024, all the way through July 4, 2026. What we found is that there is a significant volume of projects that we believe are safe harbored into one of those milestones. Our estimate is that by mid-2026, roughly 170 gigawatts of wind and solar capacity will be safe harbored into either the legacy tax credits or a technology-neutral tax credit.

Of that, we estimate about 70 gigawatts are safe harbored into the legacy tax credit rules. This is particularly meaningful because some large tax equity investors do have a stated preference for projects that are eligible for legacy tax credits. 

We do think that 2026 will have a more diverse investment environment. Some tax equity sponsors will look at tech-neutral projects, others will not, but the overall volume of safe-harbored infrastructure will sustain and maybe even increase the investment basis for the industry as a whole.

Crux: How normal have transferable tax credit purchases become in corporate tax planning?

KB: This remains both an area of study for us and a dynamic space given the evolution in corporate tax capacity enacted through the One Big Beautiful Bill.

We did find that a rising share of corporate taxpayers have announced that they are active in the tax credit market or investing in tax credits as a tax equity partner. Around 25% of the Fortune 1000 were active in the tax credit market or the tax equity market as an investor in 2025. That still means that a large portion of the Fortune 1000 are not purchasing or otherwise investing in tax credits. We know not every company is going to have a sufficient tax liability to do so, and then there are other international tax rules — such as the base erosion anti-abuse tax, or Pillar 2 requirements — which might increase the complexity of participating in these markets. So, not every Fortune 1000 company is really an eligible candidate for this market at the same time.

Nonetheless, the data shows that this is an increasingly standard practice across, in particular, large and mid-sized corporates that can navigate the complexity of the market. And as transferability in particular has become a more common instrument, we are finding that smaller companies are better positioned to be able to make these investments because the overall complexity of transacting has come down.

Crux: When overall demand slowed in the second half of 2025, deal count stayed relatively stable. What does that pattern tell us about who was active in the market?

KB: What this tells us is that companies that are generally smaller, and that were less impacted by the changes to corporate tax provisions such as the R&D extension, bonus depreciation, etc., remained active in the tax credit market, while larger corporates, which typically have more complex tax considerations, were less active. Several of the mainstay market participants — many of which are very large companies that have become accustomed to transacting with household names on the corporate taxpayer side — found that demand for very large tax credits was relatively subdued, while our data shows that the demand for smaller tax credits actually increased. 

When we say smaller credits, we're typically talking about the market between about $25 million and $100 million in notional value for those tax credits. That part of the market was really the most liquid and dynamic in the second half of 2025.

Crux: The report discusses "bring your own capacity" strategies by data centers. How is this trend reshaping clean energy investment patterns?

KB: We're finding that "bring your own capacity" or "bring your own generation" is an increasingly standard strategy for data centers. For project developers, that just means that the path to market has become more complicated. You're not necessarily only looking at a utility off-taker; you might also be looking at a large commercial and industrial (C&I) customer off-taker such as a hyperscaler.

Ultimately, this is all driven by speed to deploy. Data centers clearly prefer the fastest megawatts to market. It is one of the most important trends that we will watch over 2026 — to see both how data center power users evolve their strategy to satisfy their own speed-to-power and reliability requirements, and how federal policy and regional policy evolve to accelerate the pace at which we can bring new resources onto the grid.

Crux: If you had to identify the single most important trend or data point from this report that market participants should be paying attention to, what would it be?

KB: I would encourage stakeholders in the clean economy — whether they are policymakers or consumers or anyone across the board — to take away that our data really shows that the parts of the market that are most vulnerable to disruption and the most susceptible to policy headwinds are really the fuels and manufacturing spaces. When we look at our data, the only place where we saw overall investment decline was in fuels and manufacturing. 

I think if you are invested in seeing a robust and diverse energy economy in the United States, the signal you should take away is that policy stability and clarity are foundational to sustaining investment, in particular in some of our more nascent and difficult-to-incentivize industries.

Crux: Katie, is there anything we didn't discuss that you think is critical for developers, lenders, or tax credit buyers to understand as they plan for 2026?

KB: I think the number one thing — the elephant in the room in every conversation today — is the FEOC rules and how those will be applied.

When we look at our market and the state of investment, most market participants have active strategies to understand and incorporate the FEOC rules into their investment decision-making. But ultimately, tax credit monetization brings a lot of different stakeholders to the table, including insurance brokers, tax credit buyers, law firms, and other partners. Ensuring that we are intentional and transparent about how FEOC is being satisfied from the very beginning is increasingly going to be a consideration that projects must contend with in 2026.

Download the full market intelligence report for more insights.

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