Five business days of silence is worth 2.5¢ a kilowatt-hour.

There is a standard story about the Inflation Reduction Act’s labour rules, and every part of it is about who can afford lawyers. The rules are described as a burden, a trap, a reason small developers stay out, a thing that gets priced into deals by people with compliance departments. That story is a claim about a document, and the document is four pages of regulation plus one IRS form that anybody can download.

What the document actually does is put a published federal price on paperwork. Section 45Y pays a base amount per kilowatt-hour and a five-times amount for a facility that satisfies prevailing wage and apprenticeship. For calendar year 2026, against an inflation adjustment factor of 2.0570, the Treasury published both numbers: 0.6 cents under section 45Y(a)(2)(A) and 3.1 cents under 45Y(a)(2)(B). The investment-side credit does the same thing in percentage points, 6% of qualified investment against 30%. The gap is not a subsidy for building something different. It is a subsidy for holding a record.

A megawatt of alternating-current capacity running at a quarter of nameplate produces 2,190,000 kilowatt-hours a year. At 2.5 cents of difference that is $54,750 a year, and the credit runs ten years, so one megawatt of documentation is $547,500. Across the 43.4 GW of solar the EIA has scheduled for 2026 the same 2.5 cents is $2.38 billion a year of credit that turns on whether somebody kept the file.

Now the apprenticeship half, which is the part that is genuinely strange. Section 45(b)(8) requires that 15% of total construction labour hours be performed by qualified apprentices from a registered programme for anything whose construction began after 31 December 2023, requires every contractor employing “four or more individuals” to employ at least one apprentice, and requires the daily journeyworker ratio to hold. Miss it and the cure is $50 per deficient labour hour, or $500 on a finding of intentional disregard.

Solve that backwards. A cure of $60,000 is 1,200 apprentice hours at $50, and 1,200 hours is 15% of a project with 8,000 construction labour hours. So a single mid-sized job that employed no apprentices at all owes the Treasury, to the dollar, the annual income this page exists to find. On a finding of intentional disregard the same job owes $600,000.

And then the exception. Regulation 1.45-8(f)(1)(i)(A) requires the initial request for apprentices to be made “no later than 45 days before the qualified apprentices are requested to start work,” and any subsequent request to the same programme “no later than 14 days.” Subparagraph (B) deems the taxpayer to satisfy the statute where the request is denied, “provided such denial is not the result of a refusal by the taxpayer” to meet the programme’s standards. Subparagraph (C) is the one nobody quotes: no response within five business days and “such request is deemed to be denied.” The deemed denial covers the requested period up to 365 days.

Read those three together and the apprenticeship requirement is not a hiring requirement. It is a correspondence requirement. The 15% is owed only by a taxpayer who never wrote the letter, or wrote it late, or wrote it to a programme that answered. The $60,000 cure above and the $0 cure are separated by a dated email and a calendar entry forty-five days out.

The IRS agrees, which is the strongest evidence here. Form 7220, revised December 2025, is the form that carries all of this onto the return, and its Part V is built for the exception rather than for the hiring: column (e) is hours needed, column (f) is hours “requested and denied,” column (g) is a box for a denial and column (h) is a box for “didn’t respond.” A federal tax form has a checkbox whose value, on one megawatt, is $547,500.

The prevailing wage half is priced the same way and cures the same way. Regulation 1.45-7(c)(1) sets the correction payment at the wage shortfall plus interest at the section 6621 rate “substituting ‘6 percentage points’ for ‘3 percentage points’,” and (c)(1)(ii) adds a penalty of “$5,000 multiplied by the total number of laborers and mechanics” underpaid — so twelve underpaid workers is $60,000, again the whole year. But (c)(6)(i) waives that penalty entirely if the correction is paid “by the last day of the first month that follows the end of the calendar quarter in which the failure occurred” and either the worker was short in “not more than 10 percent of all pay periods” or the shortfall is “not greater than 5 percent.” A quarterly review that catches a misclassification inside the quarter is worth $5,000 a head.

The inputs are free. DOL’s Wage and Hour Division publishes the determinations on SAM.gov, and where none fits, a supplemental determination is requested by email to IRAprevailingwage@dol.gov “no more than 90 days before the beginning of construction.” No fee, no licence, no examination, and no credential of any kind appears anywhere in TD 9998, in Form 7220 or on DOL’s page. The qualification to do this work is that you read the regulation and start the clock on time.

The counterweight is the One Megawatt Exception, and it is the reason this is a job at all. A facility “with a maximum net output of less than 1 megawatt (as measured in alternating current)” gets the 3.1 cents and the 30% without satisfying anything, and the Form 7220 instructions say plainly that such a taxpayer is “not required to file Form 7220.” So every project below the line needs none of this, every project above it needs all of it, and the discontinuity at exactly 1 MW is $54,750 a year. The second counterweight is that no public dataset posts what this service sells for; the fee counts below are stated at several price points and flagged as derived, not observed.