Solar and wind projects in the United States had to begin construction by 5 July 2026, today, or be placed in service before 1 January 2028, to retain eligibility for the federal Investment Tax Credit and Production Tax Credit under the One Big Beautiful Bill Act signed into law in July 2025. That deadline reshaped hiring at every EPC contractor and developer in the country over the past twelve months, according to guidance published by Novogradac. New Foreign Entity of Concern (FEOC) restrictions on component sourcing also take effect in 2026, tightening eligibility rules further. The leadership question for the sector now shifts from who got projects into construction in time, to who runs completion from here, and who ends up owning the assets that didn’t make it.
Two roles that used to be one
Until this year, most developers ran a single leadership track from project origination through completion. That is splitting into two distinct roles. The VP of Development is the executive who spent the last twelve months racing projects into construction to lock in credit eligibility, someone who thrives under deadline compression and moves fast on procurement. The VP of Asset Completion is a different profile entirely: someone who manages a multi-year build toward a hard placed-in-service deadline in January 2028, where the risk is no longer speed but discipline over a long horizon. Boards are increasingly hiring separately for each, because the skill sets don’t naturally live in the same person.
A compliance role that didn’t exist before 2025
The FEOC restrictions have created a genuinely new position: Director of FEOC Compliance, typically reporting directly to the VP of Procurement rather than to Legal, because a sourcing decision made incorrectly can strip a project of its tax credit entirely. This isn’t a role that can be staffed from a generic compliance background. It requires someone fluent in both the regulatory text and the practical realities of component sourcing, a combination that barely existed as a distinct job description eighteen months ago.
| Role | What it used to require | What it requires now |
|---|---|---|
| VP of Development | Origination, permitting, deal-making speed | Deadline-driven procurement discipline under acute time pressure |
| VP of Asset Completion | Often the same person as Development | Multi-year completion management against a fixed regulatory deadline (Jan 2028) |
| Director of FEOC Compliance | Did not exist as a distinct role before 2025 | Executive-level fluency in component sourcing rules tied directly to credit eligibility |
| Head of Post-Deadline Pipeline Strategy | Folded into general strategy functions | Dedicated planning for what the sector builds once this credit cycle closes |
What the deadline did to the shape of the market
The money behind this rush is not trivial. The Congressional Budget Office estimates taxpayers will claim USD 11.9 billion in Production Tax Credits through 2026 alone, and a total of USD 51 billion on these credits by 2031. That scale explains why the race to 5 July was so uneven. Large developers with secured capital and supplier relationships locked in their projects months in advance. Mid-sized and smaller developers, more dependent on external financing and slower-moving supply chains, arrived late or missed the window entirely.
This is likely to accelerate consolidation through 2027. Developers who didn’t get projects into construction in time will probably end up selling those assets, with or without surviving credit eligibility, to the developers who did make the deadline and now hold both liquidity and a secured pipeline. For executive search, this means the next 12 to 18 months will bring a wave of post-M&A integration mandates layered on top of completion-phase hiring. The right executive for 2027 may not just be someone good at managing construction. It may increasingly be someone who has already integrated assets acquired from a competitor left out of this credit cycle.
Why the completion-phase hire is being overlooked
Most of the market’s attention over the past year went into meeting the construction-start deadline itself, which was a reasonable place to focus given what was at stake. Less attention has gone into who leads the sector once that deadline has passed, and less still into who leads the integration work that is likely to follow. A meaningful share of developers used this period to move quickly with whoever was available, rather than hiring the executive best suited to a multi-year completion phase or a consolidation wave. In Zavala Civitas’s view, this creates a near-term opening for boards willing to reassess leadership now, before completion-phase and integration pressure make a transition harder to execute cleanly. Click here to learn more about the industry and about our services.
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Methodology & Citations
Zavala Civitas combines mandate definition with market mapping across development, completion and integration-phase leadership, followed by structured assessment of tax-credit and regulatory fluency. The analysis is supported by regulatory guidance from Novogradac and federal tax-credit estimates from the Congressional Budget Office.
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