MADISON, WI, Sept. 09, 2026 (GLOBE NEWSWIRE) -- Carina Energy, a BESS development services firm that originates, develops, and permits battery storage projects for energy developers, today announced the launch of its FEOC Compliance Support practice, providing the execution infrastructure to implement Foreign Entity of Concern compliance across storage portfolios.
Key Facts:
• FEOC compliance is required for all BESS projects with a Beginning of Construction date on or after January 1, 2026. Failure to meet the material assistance threshold eliminates the entire base 30% Investment Tax Credit, not just the domestic content adder.
• Material Assistance Cost Ratio (MACR) thresholds for energy storage increase annually, from 55% in 2026 to 75% in 2030 and beyond.
• Battery cells represent 52% of grid-scale BESS equipment cost under the IRS Notice 2025-08 safe harbor table, making cell provenance the dominant variable in MACR compliance.
As of September 2026, most BESS developers lack dedicated infrastructure to screen OEMs for Prohibited Foreign Entity exposure, calculate MACR across a portfolio, or maintain documentation for tax equity diligence and OBBBA’s 10-year ITC recapture window. For developers without a specialized BESS team, FEOC adds a regulatory layer to an already unfamiliar development sequence.
Carina’s practice delivers seven core tools: an OEM FEOC Master Screen with cell provenance and ownership tracing, a MACR calculator using Notice 2025-08 Safe Harbor methodology, a Notice 2026-15 supplier certification template, effective control contract language and checklist, BOC strategy memos, and a documentation retention system. Artifacts are validated by external counsel. The screening architecture is designed to extend as procurement compliance frameworks, including the FCC Covered List and Executive Order 14420, take effect. Binding tax decisions remain with the developer’s tax counsel.
“FEOC compliance is a permitting-adjacent requirement that can stall a project just as effectively as a moratorium or a fire code rejection,” said Malaquias Encarnacion, Managing Director of Carina Energy. “We complement the developer’s existing advisors by providing the execution layer so tax counsel can make decisions against a defensible package.”
The practice team includes a legal researcher focused on FEOC regulatory monitoring and a content specialist with DOE-funded research in battery supply chain tracing. Carina also publishes a free FEOC Compliance Guide (https://carina.energy/feoc-compliance-guide-bess/), updated regularly.
Full details are available at carina.energy/what-we-do/feoc-compliance-support/.
About Carina Energy
Carina Energy is a BESS development services firm that originates, develops, and permits battery storage projects for energy developers. The firm provides specialist-led development services across nine disciplines and six project phases, from site origination through notice to proceed. Carina maintains a codified 600-task work breakdown structure, a 140-document project finance data room, and a real-time Smartsheet project management platform. The firm tracks BESS moratoriums across 150+ jurisdictions in 16 states and monitors FEOC compliance across approximately 50 OEMs. Carina is based in Wilmington, Delaware.
