What Partners Need to Know About EoY Submissions
FEOC (Mandatory Prerequisite) and Domestic Content (Optional Program) percentage thresholds increase by 5 percentage points on January 1, 2027.
A project qualifies as a 2026 installation only if it:
[A] reaches substantial completion by December 31, 2026, and
[B] has its install documentation submitted in the LightReach portal by the applicable deadline. For Solar and Energy Backup (Retrofit) projects, that deadline is 11:59 PM local time on December 31, 2026. New Homes and New Community projects follow the separate timeline described below.
In the spirit of fairness to all partners, no exceptions will be granted.
[A] What Qualifies for Substantial Completion?
All component groups on the plan set must be installed on site by the deadline. This means:
| Component | Installation Requirements |
1 | Racking & attachments | Required: fully complete; rail, splices and clamps |
2 | Modules | Required: all mounted on the racking; module count matches the plans |
3 | Inverters, optimizers, microinverters | Required: all installed in final location |
4 | Module-to-module and MLPE wiring | Required: complete, so modules are not lifted a second time |
5 | Batteries (if applicable) | Required: all installed in final location |
Non-core items that are encouraged to be completed, but not required for purposes of EoY submission & substantial completion are below. For the avoidance of doubt, a fully complete install is still required for full milestone approval, however, these items are not expressly required for purposes of the EoY submission deadline.
String, home-run & battery wiring, conduit
Gateways, load centers, transfer switches, junction boxes, rapid shutdown, disconnects, meters, main panel, tie-in equipment
Utility tie-in, inspection, PTO, energization, commissioning
[B] What Documentation Do EPCs Need to Submit?
Every installed component group listed in [A] must be shown in photos submitted with the install package in the LightReach portal. QC must be able to identify each component in the photos.
For Energy Backup (battery-only) installations, photos must show every contracted battery and any inverter on the plan set; racking and modules are required only where they are part of the contracted system.
| Component | Photo Validation Required |
1 | Racking & attachments | Fully complete photo validation including rail, splices, and clamps |
2 | Modules | Fully complete photo validation showing all mounted on the racking + count matching the plans |
3 | Inverters, optimizers, microinverters | Fully complete photo validation, all installed in final location |
4 | Module-to-module and MLPE wiring | Fully complete photo validation of install, so that modules are not lifted a second time later |
5 | Batteries (if applicable) | Fully complete photo validation, all installed in final location (where applicable) |
How Our Proof of 2026 Install Process Will Work
The submission process is straightforward:
In the portal: the EPC will attest to the install complete date. A special field will begin displaying in the portal by mid-December.
Palmetto QC confirms that date using photos of every core component, plus either the OEM monitoring portal commissioning date (if the system is commissioned) or photo metadata (if it is not yet commissioned).
The install complete date must be on or before 11:59 PM local time on December 31, 2026.
Fine Print: the LightReach portal and API (where applicable) will add a required Install Complete Date field. Entering it is the EPC's attestation that the project reached substantial completion by that date. EPCs must enter it before the ITC Eligibility Calculator runs, and its year sets the FEOC and Domestic Content thresholds applied to the project.
This is separate from the scheduled install date. If QC finds the date is not supported, the package is rejected back to the EPC to correct the date and resubmit. The install complete date must fall on or before the install submission date. Packages with mismatching or inconsistent timelines/dates will be rejected.
What Happens After You Submit
Install year is verified as part of the normal install submission review, not as a separate step. If the project qualifies as a 2026 install, it moves through the standard QC process; there is no separate eligibility notification. If it does not qualify, it is rejected with the flag “2026 EoY Submission – Ineligible.” Qualifying as a 2026 install does not waive any other submission requirement, and packages with missing deliverables will still be rejected.
Palmetto LightReach reviews each submission on its individual facts and makes all final determinations on install-year eligibility. A determination applies only to the project reviewed and does not set a precedent for other projects or change the requirements in this article.
A Note on Commissioning & Metadata
If the system is commissioned: the OEM monitoring portal shows a commissioning date on or before December 31, 2026, and the reporting devices match the plan set, with monitoring ID and access provided to Palmetto before you submit. Photos must show every core component that comprises substantial completion, installed on site. The commissioning date proves the install year, so photo metadata is not required.
If the system is not commissioned: photos must show every core component that comprises substantial completion, installed on site. Each photo must carry its original capture date and time on or before December 31, 2026 (i.e., photo metadata).
The deadline is firm: Solar and Energy Backup (Retrofit) submissions after the deadline will not qualify as 2026 installs.
Placeholder submissions: will be rejected outright; a submission must include the equipment photos that prove substantial completion.
Additional Requirements for New Homes and New Community Programs
New Homes and New Community projects require all of the above Solar submission requirements, plus an additional master CSV. Accounts in these two programs may also be submitted until December 2027. These requirements apply only to the New Homes and New Community programs.
2025 installs | Must be submitted by December 31, 2026. 2025 installs submitted in 2027 will not be accepted. |
2026 installs | Must reach substantial completion by December 31, 2026, and may be submitted in the portal after that date until December 2027. |
Proof of install year | The same install complete date and the same commissioned / not-commissioned proof rules apply as for Solar and Energy Backup (Retrofit) EPCs (see How Our Proof of 2026 Install Process Will Work), without the December 31 submission deadline. |
Master CSV | Each home must appear on the partner's list of anticipated 2026 installs (see Master CSV below).
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Master CSV Details (New Homes and New Community Only)
Applies to: New Homes and New Community EPCs only. Solar and Energy Backup (Retrofit) EPCs do not submit a master CSV and can skip this section.
Partners must also send a master CSV listing every home they anticipate installing in 2026. These projects install in batches and often submit weeks or months after completion, so the list serves as the builder's commitment to its anticipated 2026 installs and gives Palmetto LightReach a view of potential volume. It is a planning data point, not a forecast: many listed homes will choose cash or loan financing and will not come to Palmetto LightReach.
Delivery: emailed to [email protected] no later than December 31, 2026.
Columns: system address, external reference ID (such as the partner's CRM ID), anticipated or actual install date, system size, module make/model/count, micro or string inverter make/model/count, battery make/model/count, link to documentation.
Finality: the list is due by December 31, 2026. A home missing from the list does not qualify as a 2026 installation.
The CSV is an additional requirement for New Homes and New Community installs; all other standard submission criteria still apply. Each listed project must still meet the individual project submission requirements above.
FAQ
1 | I'm missing one core component. Is that okay? | No. All component groups on the plan set must be installed and photographed; packages missing photos of any component group will be rejected. |
2 | Does a partially installed array qualify? | No. Every module and every inverter or MLPE on the plan set must be installed. |
3 | Do the racking and attachments have to be fully complete? | Yes. All racking and attachments must be fully assembled, including rail, splices and clamps. |
4 | Does a mounting defect on the MLPE or racking affect eligibility? | No. Mounting defects are handled in M1 review. They do not affect substantial completion. |
5 | Do all modules have to be installed? | Yes. Every module on the plan set must be mounted on the racking, and the photos must show all of them. |
6 | Do all modules have to be wired? | Yes. Module wiring must be complete so modules do not have to be lifted again later. This protects the roof surface and the customer experience. |
7 | Does the module count have to match the plans? | Yes. The number of installed modules must match the plan set. |
8 | Do inverters, optimizers and microinverters all have to be installed? | Yes. Every micro-inverter, optimizer and string or central inverter must be installed, and QC must be able to identify each one in the photos. |
9 | Do microinverters and optimizers have to be wired or commissioned? | Wired: yes. Commissioned: no. Microinverters and optimizers must be wired so modules do not have to be lifted a second time to wire and manage cables. |
10 | Do batteries have to be installed? | Yes. Every contracted battery must be installed following manufacturer guidelines, and QC must be able to identify each one in the photos. |
11 | Does the battery have to be wired? | No. It must be mounted in its final location. Wiring and commissioning are not required. |
12 | Does string or home-run wiring have to be installed? | No. String and home-run wiring are not required for Substantial Completion. |
13 | Does module-to-module wiring need to be complete? | Yes. See #6 above. |
14 | Does rooftop or wall conduit have to be installed? | No. Conduit runs are not required for Substantial Completion. |
15 | Do the gateway, load centers, transfer switches (ATS), enclosures, junction boxes, combiner boxes or rapid shutdown devices have to be installed? | No. Ancillary electrical equipment is not required for Substantial Completion. |
16 | Do consumption CTs have to be installed? | No. While CTs are required for every contracted project, they are not required for Substantial Completion. |
17 | Do the disconnects, production meter, main panel or other tie-in equipment have to be installed? | No. They are not required, and a pending MPU will not prevent eligibility. |
18 | Does the utility tie-in have to be complete? | No. Tie-in, inspection and PTO are not required for Substantial Completion. They remain required for later milestones. |
19 | Does the system have to be energized or commissioned? | No. A commissioning date can still help corroborate the install date. |
20 | Is monitoring access needed to prove the install year? | Not for Substantial Completion. A commissioning date in the OEM monitoring portal is the strongest corroborating evidence if QC asks for it, but it may not exist yet when system wiring is incomplete. In that case the photos must stand on their own. Monitoring access has separate milestone rules, and safe-harbor EPCs must provide it at M1. |
21 | Can an electrician sign-off date prove the install date? | No. Electrician sign-off dates are not accepted as an install date. |
22 | What photo formats are accepted? | Original photo files that carry EXIF metadata (such as JPEG, HEIC or TIFF), and photos delivered through an existing photo integration with that metadata intact. Files that do not carry EXIF data, or have had it stripped (for example, by a messaging app or editing tool), are not accepted. A full PDF export of a photo capture application's project page is accepted if the individual photos are attached and each photo's capture date is included (required when the system is not commissioned). A screenshot of an export, or any other screenshot, is not acceptable. |
23 | What if the photos show only part of the system? | The project does not qualify. Submit substantial-completion photos of every core component (racking, modules, inverters/MLPE and batteries); QC must be able to identify each one. In rare cases QC may, at its discretion, accept OEM commissioning data for a single missing component, but this is an exception with a higher burden of proof and should not be relied on. |
24 | What if QC doubts the metadata? | Palmetto LightReach may request corroboration, in this order of weight: the commissioning date in the OEM monitoring portal (where available), then the final inspection document, then a PTO document where available (more common for New Homes and New Community). Palmetto LightReach is deploying tools that detect manipulated metadata; packages with manipulated metadata will be rejected. |
25 | What if the OEM commissioning date shows 2027? | If the photos fully confirm substantial completion on or before December 31, 2026, the commissioning date is disregarded. If any required photo is missing and the commissioning date is in 2027, the project does not qualify as a 2026 install. |
26 | Does a Palmetto safe-harbor battery change the install year? | No. The install year is set only by substantial completion on or before December 31, 2026. Safe harbor is a separate pathway: a project treated as having begun construction in 2025 through approved safe-harbor equipment is not subject to the FEOC material assistance thresholds. Projects using approved safe-harbor equipment follow the Safe Harbor program rules, not the install-year test in this article. |
27 | What happens to a project that does not qualify? | It is rejected. A project that fails the 2026 thresholds cannot qualify under the 2027 thresholds. |
Policy Updates
Palmetto LightReach reserves the right to update this policy at any time. Any updates will be communicated to EPC partners in writing.
Article revision 2 – November 5, 2026