A surplus of clean energy investment tax credits is giving corporate AI infrastructure buyers greater negotiating leverage on power purchase agreements.
Clean energy developers can sell federal tax credits to corporations seeking to reduce their tax liabilities, but developers are now generating credits faster than companies are purchasing them. This supply-demand imbalance is shifting bargaining power toward buyers and intensifying competition among sellers, according to Renewable Credit Management’s third quarter 2026 market report. Production tax credits remain resilient, with solar and wind credits trading at 92 to 94.5 cents per dollar of credit value. Buyers generally prefer these over investment tax credits because they are easier to evaluate and carry lower risk, RCM noted.
Investment-based tax credits for solar, battery storage, and biogas—calculated as a percentage of eligible project costs—are currently selling for 90 to 93 cents per dollar. Technology-neutral ITCs face steeper price pressure as buyers weigh uncertainty surrounding new federal rules; RCM reports those credits are clearing at 88 to 91 cents per dollar.
The market for buying and selling investment tax credits has become a central component of corporate tax planning as more firms use clean energy-generated credits to offset federal tax bills. Approximately one in four Fortune 1000 companies now participates as a buyer, according to financial services firm Crux, which facilitates transactions. Financial services companies account for 45% of market volume, while energy and utility firms represent 34%. Public filings rarely disclose both the corporate buyer and the specific credit type, but Opal Fuels, a Nasdaq-listed renewable natural gas company, recently revealed that retirement solutions provider Athene purchased ITCs tied to two of its projects. Last year, Athene bought an undisclosed portion of $17.4 million in credits from a Florida project. In March 2026, Athene and its reinsurance affiliate acquired $22.9 million in credits from subsidiary Land2Gas LLC, delivering $21.6 million in proceeds to the seller.
According to RCM, the market has transitioned from the buyer-constrained conditions of 2023–2024 to a supply-rich environment, driven largely by residential clean energy financing platforms increasingly monetizing credits to raise working capital. Sunnova, formerly listed on the New York Stock Exchange, was among the early residential solar finance companies to transfer credits, reporting $207.4 million in ITC sales in 2023 and approximately $645.5 million in 2024. Residential solar alone is projected to generate roughly $6 billion in investment tax credits in 2025, according to Reunion Infrastructure, though final audited figures for last year remain under official tabulation.
Ethanol is expected to emerge as the largest source of transferable clean fuel credits, adding to a broader influx from advanced manufacturing projects and exerting downward pressure on prices at the low end of the market, where credits are currently clearing at 87 to 92 cents per dollar. Timothy Doran, a director at RCM, noted that a “limited pool of buying capacity,” partly reflecting changes to bonus depreciation and Section 174 expensing under the One Big Beautiful Bill Act, is also weighing on the market.
The expanding supply is giving buyers greater choice, making them more selective regarding projects and transactions that carry additional compliance risk. Buyers are also demanding protection against the possibility of having to repay credit values if the IRS later determines they do not qualify. Developers are increasingly being required to secure bank-backed indemnities rather than relying solely on commercial insurance. Meanwhile, some buyers are delaying transactions until there is clearer guidance on whether credits from projects involving potential foreign entities of concern, or FEOC, will qualify.
“ITC sellers are very anxiously awaiting regulations and additional guidance so that their credits can be insured, and the buyers can feel more comfortable purchasing,” Doran said. Pricing pressure is likely to persist for ITCs subject to FEOC requirements even after further guidance is issued. RCM expects the market to remain relatively stable through the end of 2026, with stronger demand for lower-risk credits helping to support prices despite elevated overall supply. The firm noted that growing corporate participation signals a maturing market, even as the current supply-demand imbalance continues to give buyers greater negotiating leverage.