What nonprofits need to know about new solar rules in Trump’s big bill

On July 31, 2025, solar financier CollectiveSun held a webinar for its non-profit group client base to cover changes to solar policy in the One Big Beautiful Bill Act. Hosts Nicole Withrow and Lee Barken covered changes in the bill (which they referred to as “OB3”) that affect installation timelines, upcoming restrictions on projects that benefit Foreign Entities of Concern (FEOC) and potential changes to the definition of “the start of construction.”

Barken told the audience that he is a certified public accountant (CPA) “but not your CPA.” He said tax law is complicated, and the OB3 is still fluid, so people shouldn’t rely on the information presented within the webinar without advice from an advisor who is “familiar with all of the facts and circumstances in (their) particular case.”

What followed was a full accounting of the legislative process, which Barken said the legislative process that brought about OB3 referred to as both “a bit of political theater” and a “tug of war” between groups with differing priorities, before describing the situation with a most colorful metaphor of “a three-dimensional chessboard… made out of glass, floating on a beach ball, in the middle of a hurricane.”

An accompanying graphic then appeared on screen, and Barken pointed out that the chess pieces were all the same color — “all just Republicans fighting amongst each other.”

“The one takeaway from this bill… is the urgency to start now,” he said. “There is no reason to delay. The sooner you start, the more likely you are to defeat the impending policy mechanisms that are going to harm projects. Starting sooner equals better, no matter how you slice it.”

There are three coming deadlines:

• Projects that begin construction by July 4, 2026 must be placed in service before the end of the fourth year after beginning construction.

• Projects that begin construction after July 4, 2026 must be placed in service by Dec. 31st, 2027.

• Projects that begin construction by Dec. 31, 2025 also avoid restrictions on material assistance from FEOC that begin in 2026.

Barken said non-profits who pay for solar installations can continue to take advantage of “direct pay” refundable solar tax credits that allow certain entities without a large tax liability to fully claim the credits — as long as they comply with the other new rules.

Barken said forthcoming guidance on the definition of “beginning of construction” from the Treasury Department (as required by a July 7th executive order) may upend long-established “safe harbor” rules that allow projects to claim that construction has begun on the date they begin physical work of a significant nature or incur 5% or more of the final project cost.

Barken said navigating FEOC restrictions will be a major concern, calling FEOC “the sleeping giant; a juggernaut” and said “we will be spending a lot of effort making sure that we are compliant with FEOC obligations.”

He said the new rules might apply differently to suppliers and project owners based on a wide variety of factors, including ownership, control and influence by prohibited foreign entities such as Russia, China, Iran and North Korea.

He highlighted the complexity inherent for some in the nonprofit space, using the example of representatives from a Russian Orthodox church who asked “are we a prohibited foreign entity?”

CollectiveSun will hold a second webinar on August 21st to explore the FEOC complexities in more detail. People interested in attending that webinar can sign up to attend here. Find more information from the first webinar here.

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