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What the IRS’s 2026 Production Tax Credit Notice Means for the Prevailing Wage Industry

Alliant Consulting
September 21, 2026
What the IRS’s 2026 Production Tax Credit Notice Means for the Prevailing Wage Industry

On June 1, 2026, the IRS published a notice in the Federal Register (91 FR 32511–32512, Document No. 2026-10906). The agency sets the inflation adjustment factor and reference price used to calculate the Section 45 Production Tax Credit (PTC) for renewable electricity. This credit is notorious for an up to 5x multiplier tied directly to whether a renewable energy developer paid prevailing wages and met apprenticeship requirements during construction.

For prevailing wage compliance professionals, this annual notice is easy to overlook because it doesn't change the law, but it does set the dollar figures that determine exactly how much is at stake on every wind, biomass, geothermal, hydropower, and marine energy project claiming the credit this year. The notice serves as a useful annual checkpoint for confirming which compliance track a given facility falls into.

The 2026 Numbers

The notice sets two figures used to calculate the PTC for calendar year 2026:

  • Inflation adjustment factor: 2.0570
  • Reference price (wind): 3.17 cents per kilowatt hour. Reference prices for closed-loop biomass, open-loop biomass, geothermal, solar, municipal solid waste, hydropower, and marine and hydrokinetic energy have not been determined for 2026.

The notice also confirms that the statutory phaseout under section 45(b)(1) does not apply to any qualified energy resource for calendar year 2026, because the wind reference price does not exceed 8 cents multiplied by the inflation adjustment factor. In practical terms, the credit is not being reduced this year for any resource type.

Base Credit Rates for 2026

The notice translates those figures into per-kilowatt-hour credit amounts under section 45(a). The applicable rate depends on when the facility was placed in service:

Qualified Energy ResourcePlaced in Service
Before 1/1/2022
Placed in Service
After 12/31/2021
Wind, closed-loop biomass, geothermal, solar*3.1 cents/kWh0.6 cents/kWh (base)
Open-loop biomass, landfill gas, trash1.5 cents/kWh0.3 cents/kWh (base)
Qualified hydropower, marine & hydrokinetic1.5 cents/kWh0.6 cents/kWh (base, if placed in service after 12/31/2022)

*Solar was restored to eligibility for facilities placed in service after December 31, 2021, with construction beginning before January 1, 2025.

Those post-2021 "base" figures are the number that matters most to prevailing wage teams: it's the rate before the potential 5x multiplier is applied.

The 5x Multiplier: Where Prevailing Wage Comes In

Under section 45(b)(6)(A), as amended by the Inflation Reduction Act, a qualified facility's credit amount is multiplied by five if the facility satisfies requirements under section 45(b)(6)(B).

What are the § 45(b)(6)(B) requirements? The three independent ways a facility placed in service after December 31, 2021 can meet § 45(b)(6)(B) are as follows:

  • Small facility exception: maximum net output of less than 1 megawatt (measured in alternating current).
  • Begin-construction exception: construction began before January 29, 2023 — the date 60 days after Treasury and the IRS published initial prevailing wage and apprenticeship guidance.
  • Actual compliance: the facility satisfies the prevailing wage requirements of section 45(b)(7)(A) and the apprenticeship requirements of section 45(b)(8).

For any facility that doesn't fall into the first two categories, the 5x multiplier, and the difference between, for example, 0.6 cents and 3.0 cents per kilowatt hour on a wind project, depends entirely on documented prevailing wage and apprenticeship compliance during construction.

Bonus Credits Remain on the Table

The notice is also a reminder that the domestic content bonus under section 45(b)(9) and the energy community bonus under section 45(b)(11) continue to apply to facilities placed in service after December 31, 2022, layering on top of the base and multiplied credit amounts. The IRS has issued separate guidance on both: Notice 2023-38, Notice 2024-41, and Notice 2025-08 address the domestic content bonus, while Notice 2024-30 addresses the energy community bonus.

What This Means for Compliance Teams

For firms supporting developers, EPC contractors, and owners on PTC-eligible projects, it’s best practice to confirm which section 45(b)(6)(B) pathway a project relies on early. Projects claiming the begin-construction exception should have their documentation of construction start date well organized, since it's what stands in for prevailing wage compliance.

For projects that don't qualify under the small-facility or beginning-of-construction exceptions, prevailing wage and apprenticeship compliance during construction sets out the difference between the base rate and five times that rate.

Firms should also track the annual inflation adjustment factor and reference price each year; they change the dollar value of compliance (and noncompliance) even though the underlying legal requirements stay the same.

Conclusion

If questions arise regarding how prevailing wage and apprenticeship requirements apply to your project, our team is available to provide experienced guidance and support. Access expert help and reach out today.

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