Scaling PWA compliance across a utility-scale solar portfolio
Case Study
PWA compliance
How Reunion partnered with a large utility-scale solar developer to run PWA compliance across a fast-growing portfolio of projects, contractors, and long-term A&R obligations.
Overview
A large U.S. utility-scale solar developer partnered with Reunion to run Prevailing Wage and Apprenticeship (PWA) compliance across a fast-growing project portfolio. With construction active in multiple states, dozens of contractors moving across overlapping projects, and years of post-PIS alteration and repair (A&R) obligations ahead, the developer needed a single compliance system of record, and quickly. Not a spreadsheet, not a sampled report, not a one-time engagement.
The developer began with a 10-project utility-scale program on the Reunion PWA platform. After running this initial cohort of projects within the platform alongside Reunion's audit team, they moved the rest of their qualifying utility-scale portfolio onto Reunion in a single tranche of new projects. Reunion ingested 100% of certified payroll across the project portfolio, calculated compliance in real time at the project and qualified-facility level (which is not necessarily the project in a §48E context), and produced diligence-ready reports in a fraction of the time it would have taken using traditional solutions.
21
Utility-scale projects
24+
Active contracts
80+
Contractors
1,000+
Tracked workers
Project context
Program
PWA compliance
2026
Multi-Project Program
Prevailing Wage & Apprenticeship (PWA)
Utility-scale solar facilities
Project structure
A portfolio-wide compliance engagement supporting IRC §48 and §48E projects with ongoing A&R obligations and audit-ready reporting workflows.
The customer
- One of the largest independent solar and battery storage developers in the U.S.
- Multi-GW operating portfolio and a robust utility-scale construction pipeline
- Business model emphasizes long-term ownership, which means PWA obligations continue through years of A&R on every qualifying facility, not just during construction.
Project engagement
- Portfolio measured in dozens of projects and hundreds of total contractor relationships
- Active construction across multiple states, each with its own wage determinations and apprenticeship program landscape
- Single-prime, multi-prime, and shared-subcontractor arrangements, where the same EPC or subcontractor often appears on several jobs at once
- Projects qualifying under IRC §48 and §48E ITCs, with PWA non-compliance carrying material per-project recapture risk
- Shared substations and balance-of-system facilities requiring labor-hour allocation across multiple qualifying facilities
End-to-end compliance management
At this scale, compliance is a weekly operational rhythm, not a quarterly one-off task. Reunion replaced a patchwork of spreadsheets, email chasing, and consultant deliverables with one managed workflow.
Payroll ingestion
Certified payroll was uploaded alongside direct payroll integrations, automatically parsed into structured records with audit trails, and auto-matched to workers, classifications, and contracts. Reunion ingested 1,000,000+ labor hours across 9,000+ payroll reports for the initial tranche of projects.
Contractor onboarding
Dozens of contractors, from large EPCs to small site-prep crews, were onboarded onto a single platform. Contractors with certified payroll providers uploaded payroll data; others entered payroll directly into the platform.
Audit-ready review
Reunion's audit team reviewed apprentice certifications, registered apprenticeship program (RAP) documentation, Good Faith Effort requests, and wage determination assignments.
Long-term compliance tracking
Project, contractor, and work classification configurations have carried forward from construction into the five-year A&R window without rebuilding the compliance program from scratch once projects hit PIS.
Full portfolio compliance coverage under one platform
Within a year of onboarding the initial project group, the developer moved the rest of their qualifying utility-scale portfolio onto Reunion, more than doubling the size of the program without standing up a parallel workstream.
Real-time visibility
With 21 active projects and 80+ contractors on-site daily, the developer needed to see their entire project portfolio at a glance while being able to drill down into any project, contract, or contractor on demand.
Understand buyer requirements
- Reunion’s portfolio dashboard rolled up every project into a centralized view of apprenticeship participation, ratio compliance, labor-hour tracking, and wage requirements.
- During quarterly reviews, the developer and Reunion reviewed all 21 active projects side-by-side, including several already exceeding the 15% apprenticeship labor-hour threshold.
Real-time issue detection
- Any underpaid weeks, missing fringes, missing apprentice certificates, and ratio breaches surfaced as flags on the affected contractor and worker, not in a year-end report.
- In one quarter, Reunion flagged seven weeks of underpaid wages eligible for cure and surfaced contractor-level reporting anomalies (duplicate hours, excessive hours, etc.) before they turned into costly penalties for the contractor and developer.
Automated penalty calculations
- The Reunion platform calculated all backpay owed and corresponding IRS penalty exposure automatically, ensuring that contractors were always aware of their standing with respect to PWA requirements.
Contractor visibility
- Contractor-level views showed exactly which contractors were dragging down a project's apprenticeship labor hours percentage, which were missing certified payrolls, and which were performing adequately, informing both contracting decisions and contractor outreach.
Labor-hour allocation
- Shared substations and other balance-of-system assets were modeled directly in the platform, with journeyworker and apprentice hours weighted across the downstream projects so compliance metrics rolled up accurately and reflected the proper distribution of labor hours.
Quarterly portfolio review cadence
- This visibility supported a repeatable quarterly portfolio review cadence between Reunion and the developer's project finance team, where every active contract was walked through side-by-side against its labor-hour, ratio, and apprenticeship status.
- Anomalies were surfaced and resolved months before they reached a buyer or insurer rather than reconstructed at year end.
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Diligence-ready reporting
A PWA report at this scale is a transactional document that has to survive a thorough audit by tax credit buyers, insurance underwriters, and tax counsel.
Aligned early on critical reporting standards
100% payroll coverage
Reports for the developer were built on 100% of certified payroll records, eliminating the "what about the weeks you didn't sample?" line of questioning.
Real-time compliance tracking
Wage and fringe comparisons against the correct Davis-Bacon wage determination, apprenticeship requirements, and Good Faith Efforts were calculated in real-time by the Reunion platform, not re-derived in Excel after the fact.
Draft-ready reporting
The developer was able to pull a draft PWA report for any project on demand from the Reunion platform, to share with counsel or prospective buyers.
Reunion ensured audit-ready documentation
- Every final report was reviewed by Reunion's audit team to ensure that reports contained the language, structure, and supporting documentation buyers and insurers expect.
- For §48E and §45Y projects, Reunion applied the Specific Allocation Method under IRC §263A , producing facility-by-facility compliance determinations within a single integrated report.
- The result was a defensible §48E methodology, backed by 100% payroll coverage that held up in front of tax credit buyers, insurance underwriters, and tax equity counsel.
Portfolio-wide compliance
For developers at this scale, PWA stops being a per-project deliverable and becomes a formal compliance program. Reunion runs compliance programs end-to-end: from the first certified payroll on day one of construction through the final A&R report years after PIS, on one platform, under one audit team, with the same configurations carrying the entire portfolio forward.
Access the Compliance Guidebook to learn more about PWA compliance.
