Crux | 2024 transferable tax credit market intelligence report

December 31, 2024 marked the end of the first full year of transferability, a new tool to increase the value of clean energy tax credits and expand their reach. While the market for transferable clean energy and manufacturing tax credits opened in 2023, the market didn’t begin transacting until the latter half of 2023, after proposed rules were published. The market has matured rapidly since then, becoming more transparent and broadening access to capital for a more diverse range of technologies.

To understand the transferable tax credit market in 2024, Crux surveyed market participants in November and December 2024. More than 200 respondents answered detailed questions regarding their activities in the tax credit transfer market and related financing. In total, respondents reported $13 billion of transferable tax credit deals across more than 100 unique transactions.

We then integrated that survey data into our comprehensive transaction database, bringing the cumulative total deal data to $25 billion — estimated to represent 75–80% of transactions completed in 2024. The result is the industry-leading 2024 year-end market report, published today.

A dive into the data reveals that transferability is driving rapid investment into clean energy and manufacturing businesses, strengthening domestic supply chains and helping to create a more resilient energy system.

Key learnings from the historic first full year of transferability include:

1. Tax credit deal pricing remained strong throughout the year.

Pricing averaged 92.5 cents for investment tax credit (ITC) deals (up from 92.0 cents in 2023) and 95.0 cents for production tax credit (PTC) deals (up from 94.0 cents in 2023). Larger deals tended to obtain higher pricing, and PTC deals tended to price at a premium to ITCs. Several new tax credit types, including advanced manufacturing PTCs and nuclear PTCs, commanded premium prices, suggesting tax credit buyers’ increasing comfort navigating the rules for new tax credit categories.

Average pricing and demand for tax credits remained high following the election in November 2024. In total, Crux estimates $30 billion of tax credit transfers occurred in 2024, including $24 billion of 2024 transfers and an additional $6 billion of forward-market (2025 or later) sales.

2. Market transparency and liquidity drove greater convergence in tax credit pricing, especially for deals under $20 million in notional value.

Smaller tax credit deals saw the most material increase in year-over-year pricing, indicating transferability is working as intended to expand the reach of clean energy tax credits. Smaller developers have historically had very limited access to capital, and better market access allowed these credits to transact at lower discount rates. While smaller tax credits continued to price somewhat lower than larger deals, the growing liquidity in the market supported pricing on these deals.

3. The market diversified materially over the course of 2024.

By the second half of 2024, tax credits generated by newly eligible technologies such as advanced manufacturing, nuclear energy, bioenergy, geothermal, critical minerals, and carbon capture made up 72% of tax credit transactions. This was a considerable increase from the first half of the year. Over the full year, newly eligible technologies made up 52% of the market.

Many of these projects do not have access to traditional tax equity, and the data clearly shows that transferability is a leading source of new capital for them.

4. Market participants leveraged the flexibility and transparency of the tax credit transfer market.

The data shows variation in investment structures between PTC and ITC deals. More than 90% of PTC deals were direct transfer deals, while 57% of ITC deals were sold out of tax equity partnerships. That’s driven in part by newly eligible technology types. For example, the §45X advanced manufacturing PTC and the §45U nuclear PTC do not lend themselves to tax equity investment structures because availability is not tied to the facility’s placed-in-service timing.

The variation shows that developers and manufacturers were seeking the most efficient financing options based on the tax credit their projects were eligible to receive. Efficient tax credit financing helps lower project development costs, and these savings get passed to consumers in the form of lower energy costs and globally competitive manufactured goods.

5. The forward market began to take shape in 2024.

Forward commitments for tax credits made up 20% of deal volume in 2024, and deals were concentrated in the second half of 2024. These commitments provided projects with the ability to access capital efficiently and pull forward the value of their tax credits. The forward market in 2024 was particularly notable, because very few forward commitments occurred in 2023. However, by the fourth quarter of 2024, more than 30% of closed deals included a commitment to purchase tax credits in a future year.

This evolution reflects the market’s comfort with taking a longer-term view of tax credit availability, facilitated by the long-term expansion and extension in 2022, as well as the emergence of deal terms and standards that offer buyers adequate protection if projects are materially delayed or disrupted.

6. Insurance remains a common feature in many deals and is broadly accessible.

Tax credit buyers complete thorough due diligence of all tax credit transactions and routinely require indemnification against any tax credit or transaction risks. Indemnities can be provided by the seller’s parent company and/or covered by a third-party insurance policy.

Insurance is significantly more common in ITC deals than PTC deals. PTCs tend to be relatively low risk — buyers pay for the tax credits after they’re generated and typically on a quarterly basis. ITC deals are more likely to include third-party insurance coverage in part due to the risk of tax credit recapture.

More than 75% of ITC deals reportedly included a full-wrap insurance policy or a partial insurance policy. Insurance was far less common for PTC deals, with 20% containing insurance; more than 80% of PTC deals indicated that they were fully indemnified by the seller’s parent company.

Fill out the form below to download the summary 2024 market intelligence report here. The full report, which includes 20 additional pages of pricing data, is available for Crux platform users, survey participants, and partners. To receive a copy of the full report, get started on Crux.