Who buys tax credits?

Tax credit buyers are mostly large corporations with big, predictable federal tax bills, led by banks and insurers. Crux counted 98 Fortune 1000 companies buying clean energy credits in the first half of 2026, on pace to match or beat the nearly 200 that took part in all of 2025.

Those numbers come from Crux's October 2026 benchmarking report, and they include both tax equity investments and direct transfers. Its count understates the market, since year-end filings often capture purchases that quarterly reports miss. Buying has also become routine: 48 companies, just under half of the year's buyers, bought in both the first and second quarters.

Under Section 6418, a project owner can sell its credit to an unrelated company for cash. The buyer then uses it against its own taxes. That's different from tax equity, where the investor joins a partnership that owns the project. Our guide to tax equity investors covers that side of the market, and how C-corps use ITCs covers the corporate tax mechanics.

Which industries buy the most tax credits?

Financial institutions buy the most: 30% of Fortune 1000 financial companies purchased clean energy tax credits in the first half of 2026. Consumer staples followed at 16%, then consumer discretionary and energy at 11% each. Large caps participated at 13.8%, mid caps at 9.2% and small caps at 4.2%.

The pattern is about tax profile more than industry. Crux says banks and insurers suit recurring purchases because they have large, predictable domestic tax liabilities and teams used to managing risk. Staples and discretionary companies bring high, steady domestic income and mature treasury functions. Energy companies moved up as high prices lifted profits, and tax bills along with them. If you're a seller, those are the first places your buyer is likely to come from. Tap through the chart to compare the groups.

Why do companies buy tax credits at a discount?

Companies buy tax credits because each dollar of credit cuts a dollar of federal tax for less than a dollar of cash. At the 2026 average Investment Tax Credit (ITC) price of $0.913, a $10 million credit costs $9.13 million, saving the buyer $870,000 on its tax bill.

Production Tax Credits (PTCs) averaged a bit more, at $0.930, per Crux's H1 2026 review. Under 26 CFR 1.6418-2(f)(2), the buyer has no gross income from claiming the credit, even though it paid less than face value. The savings aren't free of risk or limits, though. The general business credit limit caps how much a company can use in a year, and the buyer bears the IRS risk if a credit falls short. To run the numbers from the buyer's side, see buying tax credits to reduce taxes.

Can individuals or small businesses buy tax credits?

Individuals can buy transferable tax credits, but the passive activity rules usually let them use the credits only against passive income. That leaves few individual buyers. Widely held C corporations avoid those limits, which is why they dominate the market. Partnerships and S corporations can buy, too, subject to the same rules for their owners.

Treasury kept the Section 469 rules in its final regulations, despite requests to drop them, RSM explains. 26 CFR 1.6418-3 lets partnerships and S corporations act as buyers if they're unrelated to the seller. Crux notes that some high-net-worth individuals and family offices may find these deals appealing, but it doesn't expect the market to open widely to individuals. It also says tax-exempt organizations are generally ineligible. Our guide to how to buy clean energy tax credits walks corporate buyers through the steps.

What rules limit who can buy a tax credit?

A tax credit buyer must be unrelated to the seller, must pay in cash and can't resell the credit, since each credit can transfer only once. The buyer also carries the risk: if the credit turns out to be excessive, the buyer owes the excess plus a 20% addition unless reasonable cause applies.

The cash and one-transfer rules sit in 26 CFR 1.6418-2, and Section 6418 sets out the related-party bar and the excessive transfer penalty. Because of that risk, buyers lean on the contract. Our transfer agreement guide covers the indemnity, and our notes on tax credit insurance and ITC recapture explain the backstops. The seller also needs an IRS pre-filing registration number before any transfer works.

What do tax credit buyers look for in a seller?

Tax credit buyers now look first at seller credit quality and prohibited foreign entity (PFE) exposure. In the first half of 2026, investment-grade sellers made up 60% of current-year sales and PFE-exempt credits another 25%. Only 15% came from other sellers with PFE exposure, and those deals priced materially lower.

Insurance is the reason. Crux reports that tax credit insurance largely excludes PFE risk until Treasury's guidance arrives, so buyers underwrite the seller's balance sheet and its legal analysis. Exempt credits earned premiums of $0.015 for ITCs and $0.020 for PTCs. Beyond that, buyers typically want a cost segregation report for ITCs, plus wage records. Our tax credit purchase checklist shows the full list from the buyer's side, and our FEOC guide covers the foreign-entity tests.

Sellers rarely control their rating, but they can control how ready the file is. Try the estimator below to see how much each factor could move your price.

How do you find tax credit buyers?

Sellers usually find tax credit buyers through a broker, a tax credit marketplace, an advisor or direct corporate outreach. Larger sellers may run a competitive process, while smaller ones often rely on an intermediary. Credits under $10 million still drew two to three bids each in Crux's 2024 data, in line with larger deals.

Each route trades cost for reach. Brokers and marketplaces bring a ready list of tax teams and market-standard documents, and they charge for it. A direct approach can work if you already know a company's tax department, but most sellers don't. Allow time either way: Crux says transactions can take 6 to 12 weeks, and possibly longer for first-time buyers. Insurance can be a negotiated point on smaller deals, costing about 2% to 5% of the deal versus 1.5% to 3% above $10 million. See how to sell commercial solar tax credits for the seller's steps, and our market report for current pricing.

When do tax credit buyers buy?

Tax credit buying tends to build through the year, as companies get clearer on what they'll owe. Crux says the market usually runs busier in the second half. Its survey found 60% of buyers had clarity on their 2025 tax liabilities by year-end, with another 25% expecting it by the end of the first quarter.

That cycle isn't always smooth. The One Big Beautiful Bill cut corporate tax liabilities by an estimated 20% to 30%, Crux says, and many buyers paused in 2025. An estimated $8 billion to $10 billion of 2025 credits were still available at year-end. Demand has since recovered: the second quarter of 2026 set a record at $14.9 billion, and Crux forecasts $47.5 billion to $49 billion of transfers for the full year.

For sellers, the takeaway is to start early. Investment-grade supply tends to sell first, so buyers should expect a thinner slate later in the year, and a ready file can win attention then. If you have credits to sell or tax to offset, we can help you line up the right match.

Sources

• Crux, Benchmarking F1000 participation in the transferable tax credit market

• Crux, The state of clean energy finance in H1 2026

• Crux, How PFE rules are changing tax credit diligence and pricing

• Crux, Crux's 2025 Market Intelligence Report: What tax credit buyers need to know

• Crux, Roundtable with Crux's Tax Investor Coverage team: 2026 strategies

• Crux, Transferable tax credits: The complete 2026 guide

• Crux, 4 ways developers can prepare to sell smaller tax credits

• 26 U.S.C., Section 6418

• 26 CFR, Section 1.6418-2 and Section 1.6418-3

• RSM, IRS and Treasury issue final regulations on transfer of energy credits