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Notice 2023-18 established the program under § 48C(e)(1) of the Internal

SECTION 2. CERTIFICATION

Internal Revenue Bulletin 2025-50 · 2026-10-03 edition · updated 2026-10-04 · United States

Section 48C(e)(3)(B) provides that each applicant for certification has 2 years from the date of acceptance by the Secretary of the § 48C(e) application during which to provide to the Secretary evidence that the requirements of the certification have been met.

Section 48C(e)(7) provides that upon making a certification under § 48C(e), the Secretary is required to disclose publicly the identity of the applicant and the amount of the § 48C credit certified with respect to such applicant. This notice provides the identity of the taxpayer and the amount of the § 48C credits allocated to the taxpayer with respect to projects that have been allocated a § 48C credit and for which a certification was issued during the period beginning on January 10, 2025, the day that Round 2 allocation notification letters were issued, and ending on September 30, 2025, for Round 2 of the § 48C(e) program. The IRS will publish additional such notices annually for certifications issued during each successive 12-month period beginning on October 1, 2025. Accordingly, the certifications issued to date for Round 2 of the § 48C(e) program are as follows:

Taxpayer Amount of Credit Certified
Ozinga Cement, Inc. $ 14,930,597.75
Tesla, Inc. $ 240,289,310.00

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