SECTION 5. PIN ASSIGNMENT

REQUIREMENT

.01 In General . To satisfy the PIN assignment requirement in § 25C(h)(3) (A), QMs must employ the PIN assignment system described in this section 5 (PIN Assignment System).

.02 Specifics of the PIN Assignment System . Except as provided in sections 5.03 through 5.06 of this revenue procedure, QMs must assign a 17-character PIN unique to each item of specified property. The PIN for each item of specified property is made up of three parts and may contain alphanumeric characters (including the common digits 0 to 9 and capital letters A to Z, other than I or O, ³ but not special characters such as *, &, @, etc.):

(1) Part 1: QM Code . The first part of the PIN is the manufacturer’s four-character QM Code. When the IRS validates a QM Registration Application and Agreement, the IRS will assign a QM Code to the QM.

(2) Part 2: Product Code . The second part of the PIN is one character (that is, character 5 of the PIN) and is a “Product Code.” The Product Code is assigned by the QM in accordance with a list of Product Codes on https://www.irs.gov, on the IRS Energy Credits Online Portal, or in future published guidance. This character represents the category of specified property and, if applicable, the relevant geographic climate zone.

(3) Part 3: Item Number . The last twelve characters of the PIN (that is, characters 6 through 17 of the PIN) must represent the specific “Item Number” that is unique to each item of specified prop

3 The letters I and O may not be used because they are easily mistaken for the numbers 1 and 0.

November 12, 2024 1116 Bulletin No. 2024–46

erty. The QM may choose any twelve alphanumeric characters (including the common digits 0 to 9 and capital letters A to Z, other than I or O, but not special characters such as *, &, @, etc.) for the Item Number, provided that the result is a unique Item Number, and provided that the Item Number does not employ leading zeroes. The IRS encourages QMs to employ nonsequential characters.

.03 Specified Property Placed in Ser- vice During the 2025 Calendar Year . Notwithstanding section 5.02 of this revenue procedure, for all specified property placed in service on or after January 1, 2025, and before January 1, 2026, a QM can satisfy the § 25C(h)(3)(A) PIN assignment requirement with its QM Code in lieu of its PIN. For specified property placed in service in 2025, taxpayers may use the QM code in lieu of a PIN.

.04 Enabling Property . For enabling property, regardless of whether the enabling property is placed in service after December 31, 2025, a QM can satisfy the § 25C(h)(3)(A) PIN assignment requirement by using its QM Code in lieu of its PIN, and taxpayers claiming the section 25C credit may use the QM Code in lieu of a PIN. Nothing in section 5.04 of this revenue procedure negates the need for the QM to provide a 17-digit PIN as described in section 5.02 of this revenue procedure for other specified property, or for the taxpayer to provide a 17-digit PIN as described in section 5.02 of this revenue procedure for any other specified property, including enabled property, on the taxpayer’s tax return.

.05 Heat Pumps . With respect to a heat pump that meets the requirements of § 25C(d)(2)(ii), only the outdoor unit of such heat pump must be assigned a PIN; QMs can satisfy the QM PIN requirements without assigning a PIN to the indoor unit of such heat pump. Nothing in section 5.05 of this revenue procedure negates the need for a manufacturer to register to be a QM under section 4 of this revenue procedure, despite modified requirements applicable to QMs elsewhere in this revenue procedure.

.06 Timing of PIN Assignment Require- ment in section 5.02 . A QM must assign PINs described in section 5.02 of this revenue procedure to each item of specified property that they produce beginning on

January 1, 2026, while the item is in the QM’s possession. For items of property that the QM produces before January 1, 2026, the QM may, but is not required to, assign PINs in accordance with section 5.02 of this revenue procedure, during the manufacturing process, or after items are no longer in the QM’s possession, provided that the QM furnishes the PINs to taxpayers within the time frames set forth in section 6 of this revenue procedure.

.07 Examples . The following are example of PINs that satisfy the PIN Assignment System requirements.

(1) XYZ Corp manufactures energy efficient windows that meet the relevant standards in the northern climate zone to qualify for the § 25C credit. On January 6, 2025, XYZ Corp’s authorized representative timely and properly executes and submits a QM Registration Application and Agreement on behalf of XYZ Corp. On February 3, 2025, the IRS notifies XYZ Corp that the IRS validated XYZ Corp’s QM Registration Application and Agreement and assigned “A1A1” as the company’s QM Code.

(2) During the 2025 taxable year, XYZ Corp manufactures a line of energy efficient windows that meets the relevant standards in the northern climate zone to qualify for the § 25C credit for the 2025 taxable year. XYZ Corp calls this product line the Red window models. In the 2025 taxable year, XYZ Corp sold 2,500 Red windows, and received 2,000 requests for PINs from taxpayers. XYZ Corp must provide the QM Code, “A1A1,” to those taxpayers in the 2025 taxable year. If any of the Red windows are placed in service in the 2026 taxable year or later, assuming the windows still qualify for the § 25C credit, then XYZ Corp must provide taxpayers with the 17-digit PIN as described in section 5.02 of this revenue procedure.

(3) In the 2026 taxable year, XYZ Corp manufactures two lines of energy efficient windows that meet the relevant standards in the northern climate zone to qualify for the § 25C credit. XYZ Corp calls these product lines, respectively, the Blue and White window models. XYZ Corp manufactures 10,000 Blue windows and 10,000 White windows in 2026, or 20,000 windows in total. The Product Code for both lines of XYZ Corp’s windows is “2,” based on the northern climate zone.

(4) XYZ Corp assigns PINs to its items of specified property while they are still in XYZ Corp’s possession, as follows:

(a) Characters 1 through 4 of the PIN for each of the 20,000 windows are the characters in the company’s QM Code, “A1A1.”

(b) Character 5 of the PIN is “2” representing each window’s Product Code.

(c) XYZ Corp assigns Item Numbers “BLUE12345000” through “BLUE22344000” as characters 6 through 17 of the PIN for the 10,000 Blue windows and Item Numbers “WHITE5678900” through “WHITE6678800” as characters 6 through 17 of the PIN for the 10,000 White windows.

(5) For example, XYZ Corp will assign the PIN “A1A12BLUE12345000” to the first 2026 taxable year Blue window to which XYZ Corp assigns a PIN and the PIN “A1A12WHITE5740100” to the 613 ^th 2026 taxable year White window to which XYZ Corp assigns a PIN.