U.S. Treasury and IRS Release Final Regulations for Clean Hydrogen Production Tax Credit
Key Ideas
  • The final regulations for the Clean Hydrogen Production Tax Credit focus on changes to the calculation and accounting of hydrogen life-cycle emissions.
  • Key updates include new rules for using the 45VH2-GREET model, updated rules for energy attribute certificates, and final rules for accounting methane-derived hydrogen pathways.
  • The three-pillar framework for energy attribute certificates, focusing on incrementality, time matching, and deliverability, remains consistent to ensure clean hydrogen production with minimal environmental impact.
In January 2025, the U.S. Department of the Treasury and the Internal Revenue Service released final regulations for the Clean Hydrogen Production Tax Credit under Section 45V of the Internal Revenue Code. The regulations outline changes from the original proposal, emphasizing modifications in the calculation and accounting of hydrogen life-cycle emissions. One significant update is the implementation of new rules concerning the use of the 45VH2-GREET model to determine life-cycle emissions, with a discussion on potential future model enhancements. Additionally, there are updated guidelines for energy attribute certificates (EACs), which now include hourly tracking of electrolysis-hydrogen life cycle emissions starting in 2030. The final rules also address the life-cycle accounting of methane-derived hydrogen pathways. Despite these changes, the three-pillar framework for EACs, focusing on incrementality, time matching, and deliverability, has been maintained to ensure that hydrogen production remains environmentally friendly. This framework aims to guarantee that hydrogen is generated using clean electricity and that the production process does not divert clean electricity sources from other essential uses.
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