As the 2026-2027 Program Year continues and the initial submission window for the Illinois Solar for All: Residential Solar (Small) sub-program approaches on September 14, 2026, the Illinois Solar for All program [CR1] would like to provide guidance on the Energy Sovereignty requirements in ILSFA. More specifically, the Program Administrator would like to outline the requirements on the Energy Sovereignty REC adder, the Energy Sovereignty Payment, and the Energy Sovereignty Proposed Transfer Date. While this announcement contains valuable information, we still encourage you to read your Renewable Energy Credit (“REC”) Contract for more details.
Role of the Energy Sovereignty Proposed Transfer Date
Seller proposes the Energy Sovereignty Proposed Transfer Date in its ILSFA Part I Application.
- Section 1.55 of the 2026 REC Contract explains that the Energy Sovereignty Proposed Transfer Date is proposed by Seller in its ILSFA Part I Application and subsequently recorded in the Schedule A as “the date a transfer of ownership of the Designated System to eligible customers will occur that would allow such Designated System to achieve Energy Sovereignty.”
- The Energy Sovereignty Proposed Transfer Date, as indicated in Schedule A, is also recorded in the applicable Schedule B. The Energy Sovereignty Proposed Transfer Date is not adjusted on the Schedule B.
- Section 2.7(c) of the 2026 REC Contract explains that if Seller fails to transfer the project by the date that is two years after the Energy Sovereignty Proposed Transfer Date, the project will be removed from the REC Contract. Upon removal of the project, the Buyer shall be entitled to the full value of the invoice and forfeits Collateral.
The Energy Sovereignty Proposed Transfer Date dictates the amount of the Energy Sovereignty Price Adder to the Contract Price.
- Section 1.53 of the 2026 REC Contract defines the Energy Sovereignty Payment as the multiplicative product of:
- (a) the Energy Sovereignty Price Adder of $10 per REC,
- (b) the Designated System Contract Maximum REC Quantity, and
- (c) the result obtained by dividing (x) the number of days remaining in the Energy Sovereignty Calculation Period from (and inclusive of) the Energy Sovereignty Proposed Transfer Date by (y) the number of days in the Energy Sovereignty Calculation Period.
- The percentage in (c) depends upon the number of days between the Energy Sovereignty Proposed Transfer Date and the end of the 15-year delivery term. If an Energized project does not transfer by its Proposed Transfer Date, the percentage in (c) will decrease proportionally to the date of actual ownership transfer.
- Section 1.52 of the 2026 REC Contract defines the Energy Sovereignty Calculation Period as the period (i) starting on the date of Energization, and (ii) ending on the day that is five thousand and four hundred seventy-eight days after the date of Energization.
Payment Adjustments for Energy Sovereignty Projects
Projects receive the Energy Sovereignty Price Adder as established in the Schedule B by transferring ownership before or on the Proposed Transfer Date.
- The Contract Price in Schedule B applicable to Energy Sovereignty assumes a project will transfer by its Proposed Transfer Date. If the actual ownership transfer occurs after the Proposed Transfer Date, that project will have an adjusted Energy Sovereignty Calculation Period and will be subject to a payment adjustment.
- Section 5.7(c) of the 2026 REC Contract explains that if Seller fails to transfer the ownership of the project by the Energy Sovereignty Proposed Transfer Date, an automatic two-year grace period will be granted for the transfer to occur. However, a Payment Adjustment will occur to account for the late transfer of the project (i.e., after the Proposed Transfer Date).
- If the date the transfer occurs is after the Proposed Transfer Date and after the Project has been Energized (Part II Approved), an Energy Sovereignty payment adjustment will apply.
- If a Project’s Actual Transfer Date occurs after the Proposed Transfer Date but before the Project has been Energized (Part II Approved), the Energy Sovereignty payment adjustment will not apply.
As explained above, the Energy Sovereignty Calculation Period starts on the date of Energization
- Section 1.52 of the 2026 REC Contract, the Energy Sovereignty Calculation Period does not begin until a project reaches its Energization Date. As a result, ownership transfers that occur before Energization are not subject to a payment adjustment, even if the project is transferred after the Proposed Transfer Date established in the applicable project’s Schedule A.
If Approved Vendors have any questions regarding how contract provisions may affect projects, please reach out to your Approved Vendor Manager. For Energy Sovereignty projects under contract before the 2026-2027 Program Year, please consult the coinciding section of your REC Contract to review these contract provisions.