FEOC in Practice: Compliance, Costs, and Capital

Synopsis

With FEOC rules in force since January 2026, developers and financiers are already dealing with the realities of enforcement. This session examines the first 90 days of compliance: which suppliers are passing scrutiny, how financiers are adapting covenants and diligence, and whether domestic supply can scale to fill the gap. Speakers will share hard lessons from early projects, highlight the costs of traceability and certification, and debate how FEOC will reshape sourcing, contracting, and capital flows for storage in 2026 and beyond.

• How are developers balancing timelines against the need to source compliant kit – delay projects or proceed with risk exposure?
• What tools and processes are proving most effective for traceability and verification of components, and what costs are being added to projects?
• How are financiers, tax equity, and transferability buyers adjusting covenants, warranties, and diligence to reflect FEOC risks?
• Is domestic manufacturing capacity scaling fast enough to absorb redirected demand, and how are developers structuring contracts or JVs to secure supply?