On June 18, 2024, the Department of Treasury and IRS released a Final Rule on prevailing wage and apprenticeship provisions related to the Inflation Reduction Act (IRA).
The IRA, signed into law on August 16, 2022, introduces prevailing wage and Registered Apprenticeship requirements for taxpayers involved in the construction, alteration, or repair of clean energy facilities to receive increased tax benefits.
The U.S. Department of Labor’s Office of Apprenticeship supports the implementation of these apprenticeship requirements.
Key Provisions
Prevailing Wage and Apprenticeship Requirements
Apply to facilities where construction begins 60+ days after Treasury/IRS guidance.
Applicable to facilities starting construction on or after January 29, 2023.
Specific Credits/Deductions:
Alternative Fuel Refueling Property Credit
Production Tax Credit
Credit for Carbon Oxide Sequestration
Credit for Production of Clean Hydrogen
Clean Fuel Production Credit
Investment Tax Credit
Advanced Energy Project Credit
Energy Efficient Commercial Buildings Deduction
Prevailing Wage Provisions:
New Energy Efficient Home Credit
Zero-Emission Nuclear Power Production Credit
High-Demand Sectors
Construction
Clean Energy
Registered Apprenticeship Resources
Tools and Resources:
Partner Finder Tool
Occupation Finder Tool
Standards Builder Tool
Express Interest Portal
State Offices for assistance and support
FAQs on Registered Apprenticeship Requirements
Apprenticeship Requirements: Labor hours, ratio, and participation requirements.
12.5% to 15% labor hours by apprentices.
Apprentice to journeyworker ratios.
Definitions:
Qualified Apprentice: Participant in a Registered Apprenticeship program.
Journeyworker: Skilled worker in an industry.
Registered Apprenticeship Program: Industry-driven pathway with work experience, wage increases, instruction, and credential.
Recordkeeping and Compliance
Maintain records for compliance with apprenticeship requirements.
Written requests for apprentices, agreements, and participation records are necessary.
Wage Considerations
Apprentices can receive lower wages if part of a registered program.
Compliance with local, state, and federal wage laws is mandatory.
The IRA's integration of apprenticeship and wage requirements aims to enhance clean energy job quality and expand workforce training pathways, leveraging Registered Apprenticeships to create a skilled workforce for the future.