Monthly Market Digest for Sellers - September 2025

Starting in August, we have observed a wave of 2024 deals rushing to close, as buyers and sellers approach their final tax filing deadlines. We have been surprised by the volume of last-minute deals; Reunion is currently working to complete over $500M in transactions across more than a dozen deals with a 9/15 or 10/15 filing deadline.

Please reach out if you have credit opportunities that you would like to place with our pool of corporate buyers for the 2024, 2025, or 2026 tax years. We are seeing particular demand for:

• Last-minute 2024 tax credit opportunities of any size
• Large ($150M+) opportunities for the 2025 or 2026 tax year

Read on below for our September Market Digest series, which highlights Reunion’s market observations and recent deal highlights.

What we’re seeing in the market:

More buyers are coming to the table with specific pricing and terms in mind.

We view this as a sign of market maturity, as buyers have a clearer sense of terms they believe are fair. We have also observed more buyers who have successfully lined up internal approvals in advance and have a mandate to identify credits that meet certain criteria. Some examples of buyers with specific requirements on pricing and terms:

• Investment-grade buyer looking to pay $0.92 for 10-year PTC strips at a volume of up to $50M / year.
• Investment-grade buyer looking to pay in the low $0.90s for a forward commitment for 2026 ITCs, with transaction sizes of $175M and above. Requires tax credit insurance.
• Experienced buyer looking to pay $0.95 or better for “lowest risk” PTCs or AMPCs, with transaction sizes around $100M. Requires a seller with an investment-grade rating or a creditworthy balance sheet.

More buyers are willing to forward commit to credits for 2026 and beyond.

• While forward commitments for ITCs have been sparse in the past, we are seeing more taxpayers interested in committing now to get better deals for the 2026 or 2027 tax year.
• Buyers looking to forward commit to ITCs tend to be larger taxpayers who are comfortable making investments in advance, given their predictable annual tax liability. We find that taxpayers looking for ITCs below ~$15 or $20M tend to be more “opportunistic,” and look for tax credits as the year progresses or as their tax payments come due.
• We are also seeing buyers of various sizes look to lock in 10-year PTC strips at a discount.

The Treasury Department released new beginning of construction (BoC) rules for purposes of determining the timing of credit eligibility for wind and solar projects. We anticipate an uptick in developers that will need to find ways to use on-site physical work to establish beginning of construction.‍

• The Treasury Department released new BoC guidance that came into effect on Sept 2, 2025, that requires wind and solar projects to establish beginning of construction by starting physical work. The 5% safe harbor, which has widely been used in the past, now only applies to solar projects below 1.5MW.
• Many larger developers had planned to use transformer procurement as their BoC strategy, which qualifies as physical work and will continue to be respected under the new rules.
• Developers that did not plan to use a transformer or other off-site physical work strategy may not find it easy to procure transformers on short notice or favorable terms. We anticipate developers will increasingly use on-site physical work to establish BoC.
• Reunion offers a compliance product that helps developers establish and substantiate on-site physical work BoC.

Highlights from Recently Closed Transactions

Project Pinnacles | $45M in 2024, §48, §30C, Portfolio of onsite solar, storage and EV charging

Reunion efficiently structured this transaction between two publicly traded companies. The transaction involved the transfer of credits from three different technologies and two different credit types across many discrete projects.

What was interesting about this transaction:

• Portfolios of distributed generation assets have been traditionally the most challenging to transact on;
• Reunion’s efficient but comprehensive due diligence process was instrumental to a streamlined execution.

Project Cascades | $9M in 2024, §48, Portfolio of residential solar systems

Reunion arranged the sale of a portfolio of residential systems between a privately-held equipment manufacturer and a residential solar developer, inclusive of energy community and low-income community bonus adders.

What was interesting about this transaction:

• There is still a steep learning curve for tax credit buyers around residential solar tax credits;
• Reunion helped a buyer evaluate the key risks unique to resi and execute its third credit transfer transaction.

Project Acadia | $18M in 2025, §45, Onshore wind

Reunion facilitated this sale between a publicly traded Fortune 500 company and a diversified multinational company. This transaction represented the second sale of credits from this wind portfolio, each to a different buyer.

What was interesting about this transaction:

• These credits represented PTCs generated in the tenth year of operation, so Reunion conducted due diligence on the placed-in-service dates of the facilities based on documentation from 2015.

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