Energy in Motion conference recap: Key takeaways from the conversations happening on the ground

  • October 16, 2025

PwC’s Energy in Motion conference presented a dynamic series of panels focused on trends in energy investments, tax policy and tariffs, renewables, supply chain strategy and our thoughts on how the “One Big Beautiful Bill” is transforming tax credit financing and deal structures. Check out the panel recaps below to gain key insights on how to drive smarter, faster value creation in an evolving business landscape. Also, read PwC’s America in Motion for our latest views on policies, trade and regulations.

For energy investment, the calculations keep changing

Keeping pace with energy trends is more challenging than ever before. Companies and investment firms have found themselves recalibrating strategies and expectations based on new generation and storage technologies, significant changes in (often clashing) federal and state tax incentives and shifting overseas regulations and market trends. Driving both investment and the national energy conversation: power demand that is surging everywhere.

The energy investment landscape has been correspondingly unpredictable with many crosswinds; there has been regulatory and legislative pressure on certain credits sunsetting some provisions and adding requirements on qualifying content, while other credits have remained or have been expanded. At the same time, the rapid growth in energy demand, from rising electrification as well as data centers, has entered the equation to keep the focus on renewables. As a result, investors are still bullish on renewables, and optimism in private equity continues to climb.

Our panel on trends in energy investments discussed how the recent pullback on incentives for renewables has changed some calculations: Many investments originally made to take advantage of credits are going away. However, companies are proceeding with economically viable projects. With a huge amount of battery capacity set to come online, panelists predicted a cycle of M&A emerging for physical energy assets as well as continued growth in the tax credit market.

Solar projects look to dominate new energy capacity, though the momentum is beginning to decelerate after years of explosive growth. Investment in storage and gas is accelerating dramatically, while wind growth is slowing.

Among the themes this panel covered:

  • Perhaps counterintuitively, oil production increased under the last two Democratic administrations. Part of the explanation: States have tended to create demand catalysts in response to federal incentives and regulations.

  • Fast-rising energy demand may weaken the current administration’s resistance to solar power. Don’t be surprised if federal policies and incentives shift as needs increase. 

  • There’s a gap between conversation and generation, most notably with regard to nuclear power. There is a lot of discussion around this energy source, but its near-term impact on the national power supply will likely remain minor.

Read more:

PwC’s US Deals 2025 midyear outlook
Fueling US growth: innovation and agility in AI, energy and manufacturing
Shaping the next era of nuclear energy

Changing tax considerations for renewable projects

Many developers and investors are struggling to assess the evolving market for transferable clean energy credits, direct pay and new financing vehicles. The energy market has seen dramatic shifts over the past three years, as companies and investors deal with the ramifications of, first, the Inflation Reduction Act and, now, the One Big Beautiful Bill Act. Beyond the prediction that energy demand will continue growing rapidly, figuring out where the development market is going requires some soothsaying.

Our panel saw the market fully stratified by risk, with investors looking for backstops on companies’ balance sheets and new, sophisticated financing tools coming into play. An active tax credit investment market will be key, and analysts expect private capital to take an ever-larger role in projects.

Among the topics this panel covered:

  • Investment firms are struggling to gauge the tax credit market in the short and long term. The demand for tax credits has diminished since 2024, given favorable domestic tax changes decreasing appetite. But supply remains high and the market remains robust.
  • Recent Treasury guidance gave renewables developers until July 2026 to qualify for certain federal tax incentives, presenting a tight deadline for the end of the 5% safe harbor rule for wind and utility-scale solar energy projects. Developers need to develop a robust safe harbor strategy.
  • Robust FEOC (foreign entities of concern) rules may seriously affect the availability of battery and solar capacity, with major impacts on both development plans and investment and tax credits.

Read more:

The new energy credit landscape: Fast changes, big opportunity
Capital projects and infrastructure
Sustainability News Brief

How policy shifts and tariffs are reshaping US energy projects

An unusual number of federal-level developments look to have an outsized impact on company leaders trying to anticipate the administration’s next move and stay ahead of potential problems. Our panel took a candid look at the legislative and regulatory landscape affecting the energy industry, focusing on shifting energy incentives and tariffs that may impact the costs and timelines of energy project development.

Tariffs are on everyone’s mind, particularly those affecting products at the heart of energy industry infrastructure, from solar panels to steel and aluminum. As panelists noted, no one is completely clear on the long-term impacts of the administration’s tariff strategy on prices, supply chains or anything else. Companies, many currently working to renegotiate the price of critical materials such as copper, should watch developments carefully.

The panel also discussed:

  • There is tension between the administration’s approach to solar and wind power and some Republican senators’ support for renewable energy that benefits their states. The US Treasury Department has had to strike a balance in developing guidance.
  • Legislation and regulation are increasingly incorporating complex FEOC rules, but some Republican senators are concerned that strict implementation would hold back development of even conventional energy infrastructure.
  • Corporate leaders should be open-minded about the changing tax policy landscape and about which legislators or policymakers might be willing to listen to concerns and work to change rules.

Read more:

IRS Notice sheds light on construction rules for wind and solar credits
How to quantify sustainability factors in dealmaking | PwC Global
Translating the tax bill for business: How should executives prepare?

FEOC and beyond: Addressing supply chain challenges

News headlines suggest that companies are scaling back their sustainability initiatives. A deeper look at available data suggests a slightly different story. PwC’s Second Annual State of Decarbonization Report shows that 37% of companies are increasing their climate ambitions while only 16% are getting less aggressive. What’s behind this? Demand for power is only rising, and the need to tap solar, wind and other low carbon sources is becoming a business imperative, particularly with climate-related volatility threatening business continuity and resilience.

But leaders face supply chain challenges, not least in building the infrastructure that makes clean energy use possible. New federal FEOC rules are prompting companies to increase scrutiny of their supply chains and enhance related data collection efforts. Financing renewable energy deals can involve a daunting number of stakeholders and, with tax credits at stake, it’s important to get the documentation right and socialize it with other parties, to prove vendors’ eligibility if necessary. The volume of required information and the tracking of that data for due diligence should only continue to grow, as other supply chain partners also strive for compliance.

Collecting, monitoring and analyzing data of sufficient granularity can be onerous. Our panelists suggested looking to the enormous amount of publicly available data on suppliers and business operations and leveraging AI-based capabilities to pull together information in useful form.

Our panel also discussed:

  • Circularity is increasingly important in some industries looking for a systemic approach that reduces waste and enhances resource efficiency. Companies that have figured out circularity are measurably reducing waste, recovering rare earth minerals and seeing significant cost benefits.

  • Given the new FEOC rules, companies will need to determine their material assistance cost ratio, or a project’s direct costs that come from inputs provided by a foreign entity. A manufacturer, for example, will need to bring together the tax function, legislative affairs and operations among other departments to compile the relevant data from vendors and suppliers.

Read more:

PwC’s Second Annual State of Decarbonization Report
Why companies should start to reconsider the business case for circularity
Navigating the energy credit landscape after H.R. 1

The shifting state of the energy tax credits market

In the wake of the passage of the One Big Beautiful Bill Act (OBBBA), many corporate leaders paused major decisions on energy deals to sort through the ramifications of new compliance issues and dramatically shifted tax incentives. Some businesses have moved to reduce exposure to renewables, responding to shareholder calls to focus on core competencies. The landscape for tax credits was particularly hazy, and only now is clarity emerging.

Our panelists discussed the state of the tax credits market, including new financing vehicles and the impact on M&A in upcoming months. OBBBA and IRS Notice 2025-42, which eliminated the 5% safe harbor for most wind and solar facilities, have introduced new considerations around credits and have driven a reassessment of the state of renewable energy in the United States.

Analysts expect a round of energy deals in the next year, with more involving solar and storage and dramatically fewer involving wind. De-risked projects may have little trouble finding financing, but every contract will need provisions about diligence and material assistance, and companies don’t necessarily have those systems in place. Sellers will have the added burden of compliance with new FEOC rules, requiring close monitoring of supply chains in 2026 and beyond.

Among the topics this panel covered:

  • On FEOC, leaders are looking for further Treasury guidance as the tax credit marketplace becomes more competitive. Analysts expect guidance in the next month or two, in the form of a notice, months ahead of an official regulation. Shifting rules on the clean energy credits in sections 45X and 45Z are far more straightforward for companies to incorporate.

  • Surprisingly often, companies have little visibility into who owns their debt. With FEOC compliance rules, many are asking their lenders for attestation that they’re not foreign entities, which those lenders may be unprepared to provide. Organizations may currently lack the tax expertise — or the data — to confidently claim full compliance.

  • Some companies’ positive experience with tax credits is leading to an uptick in leaders expressing interest. Demand is increasing for safe, investment-grade insurance-backed credits. But the supply of those safe credits is limited, and at some point the financial margin could be too narrow to be worth the bureaucratic effort.

Read more:

IRS Notice sheds light on construction rules for wind and solar credits
Navigating the energy credit landscape after H.R. 1
Prevailing wage and apprenticeship services

Navigating a new era for energy

As the 10th anniversary of the Paris Agreement approaches, sustainability advocates can point to extraordinary achievements, with spending on renewable energy way up and rising. But the much-vaunted clean energy transition is not yet a reality. Globally, energy production is still in the addition phase, with fossil fuels being used alongside other sources, versus a substitution phase where wind and solar replace other sources like coal.

The key driver of energy policy change is a global shift from economic integration and cooperation to economic fragmentation, protectionism and competition. Energy security is now at the top of national agendas, with many countries looking to build resilient portfolios and move toward energy independence. But governments have to be willing to pay a premium for energy security and independence. That investment requires capital and it’s unclear where that capital might come from.

Our panel addressed the ongoing tension among energy security, energy affordability and environmental concerns. People first want to feel secure, that energy is available and affordable, before other factors come into play.

The panel discussed:

  • An uncertain policy environment, nationally and internationally, will likely persist. Expect the pendulum to swing further in both directions. The problem is that companies can’t sit still. Doing nothing is not an option.

  • Nuclear power may play a larger role in coming years. It will be challenging for the United States to achieve net-zero without nuclear.

  • Nations looking to bolster energy security and independence by leveraging renewables are struggling with supply chain issues as they try to acquire and install equipment.

Contact us

J.C. Lapierre

J.C. Lapierre

US Sustainability Transformation & Operations Leader, PwC US

Bobby Marandi

Bobby Marandi

Sustainability Tax Leader, PwC US

Kevin O’Connell

Kevin O’Connell

Sustainability Assurance Services Leader, PwC US

Ron Kinghorn

Ron Kinghorn

Sustainability Advisory Services Leader, PwC US

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