According to a recent LinkedIn post from Concentro, the Internal Revenue Service’s new Form 7220 will be a key requirement for projects seeking the prevailing wage and apprenticeship (PW&A)–enhanced 30% investment tax credit (ITC) rate for the 2025 tax year. The post notes that the form became available in January 2026 and is now a mandatory attachment for any project claiming the enhanced credit.
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The company’s LinkedIn post highlights that Form 7220 must be filed separately for each facility and then annually for as long as prevailing wage requirements apply, introducing an ongoing compliance obligation. The post also underscores the detailed data required, including wages paid, apprentice hours, deficient hours, and cure payments, implying that project developers may face higher administrative and record-keeping burdens.
As shared in the LinkedIn commentary, Concentro suggests that buyers of transferable tax credits should ensure PW&A documentation and Form 7220 compliance are addressed in transaction agreements. For deals already signed without such provisions, the post indicates that buyers may want to verify that sellers can meet the new filing requirements, given that failure to comply could jeopardize the enhanced ITC rate.
For investors, the post suggests that renewable and infrastructure projects relying on the full 30% ITC may experience additional compliance costs and potential timing risks if documentation is incomplete or delayed. It also points to a growing advisory opportunity for firms that can guide developers and tax-credit buyers through IRS documentation requirements, which could strengthen Concentro’s role in specialized tax and transaction advisory services tied to energy-related incentives.