IRS Now Splits Solar Panel and Roof Depreciation Rules

February 16, 2026
5 min read
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Fist Solar - Solar Energy & Home Efficiency

IRS Separates Solar and Roof Depreciation Rules

The Internal Revenue Service has released guidance that distinguishes depreciation for solar energy systems from roof structures. This change addresses previous ambiguities in treating rooftop modifications as part of solar installations. Developers and building owners now face clearer rules for cost recovery in commercial and residential projects nationwide.

Analysts predict this separation will affect investment planning, especially in commercial settings where roof work often comprises a substantial share of expenses. EPC firms and tax experts view the update as a step toward standardized practices that reduce audit risks.

Key Changes in IRS Guidance

Prior to this clarification, taxpayers struggled to classify roof reinforcements or replacements made for solar arrays under the Modified Accelerated Cost Recovery System. Some grouped these costs with solar equipment for faster depreciation, while others separated them based on project specifics.

The IRS now mandates treating photovoltaic modules, inverters, racking, and wiring as distinct from the roof. Solar components follow a five-year MACRS schedule, whereas roofs align with longer building depreciation periods, typically 39 years for commercial properties.

Only elements directly generating or facilitating electricity qualify as energy property for tax credits and accelerated schedules. Supportive roof materials, even if installed concurrently, count as building improvements ineligible for solar benefits.

Reactions from Solar Professionals

Tax specialists in the industry welcome the ruling for its alignment with asset functions. Rachel Kim, Tax Director at SolEdge Consulting in California, notes, "This guidance provides the consistency that many developers have wanted for years. It separates the renewable energy equipment from the building asset in a way that aligns with both physical and functional use."

Companies anticipate revising cost models to isolate solar elements. In large rooftop installations, roof preparation can represent 10 to 25 percent of total costs. With roof portions now depreciated slowly, return calculations will adjust, potentially extending payback periods slightly.

This shift encourages precise allocation in financial projections and loan terms, favoring projects with minimal roof intervention.

Effects on EPC Firms and Developers

EPC providers must enhance contract details to delineate solar from structural costs. The guidance stresses documentation that proves separations, avoiding blended classifications during reviews.

Mark Alvarez, Operations Manager at SunMount EPC in Texas, explains, "From a design and contracting standpoint, we will have to be more deliberate about how we define roof work. When we reinforce a roof to support modules, that portion is not energy property. Only the racking, modules, and electrical equipment are. We now need to show that distinction clearly in our cost reporting."

Portfolio developers, particularly for warehouses and retail spaces, will recalibrate strategies. Previously, integrating roof upgrades with solar maximized tax efficiency; now, such bundling offers less advantage, prompting standalone approaches for tax purposes.

Details on Mounting and Attachment Systems

The ruling specifies treatments for support mechanisms. Ballasted racking, anchors, and piles dedicated to solar qualify as energy property. Permanent reinforcements or membrane replacements to handle loads, however, fall under building expenses.

For roofs needing upgrades due to age or capacity limits, full replacements remain non-qualifying for solar depreciation. Direct solar attachments alone receive benefits.

Roof-integrated systems pose nuances: electricity-generating parts may qualify, but the roofing function does not. Developers should conduct cost segregation analyses to apportion values accurately.

Influences on Financing and Investments

Financiers are evaluating impacts on tax equity deals, where depreciation timing affects cash flows. CleanTech Research Group estimates a 2 to 5 percent drop in initial benefits for projects that bundled costs previously.

David Lin, Chief Financial Officer at Skyline Solar Partners in New York, observes, "It reduces some of the blended benefits on integrated roof projects, but it also gives us certainty. Certainty is valuable in itself. Investors can now model depreciation more precisely without worrying about future reclassification risk."

This predictability may stabilize pricing in power purchase agreements and attract conservative investors seeking defined risks.

Broader Policy and Market Considerations

Issued during emphasis on clean energy expansion, the guidance maintains credit access while refining property definitions. Similar distinctions apply to other renewables, like geothermal, separating core systems from infrastructure.

In the commercial solar landscape, robust records become essential. Advisors urge early cost studies to categorize expenses, ensuring compliance and maximizing eligible deductions.

Adaptation Strategies for Contractors and Owners

Contractors should update templates to itemize solar and roof elements distinctly, facilitating accurate claims and audit defenses.

Owners benefit from phased projects: handle roof work independently before solar installation to streamline treatments. This sequence preserves efficiency without tax complications.

To offset depreciation shifts, prioritize efficient designs that boost output per area, enhancing overall economics.

Strengthening Project Planning with Defined Rules

This IRS update fosters reliable accounting in rooftop solar growth. Though upfront benefits may dip for some, the clarity bolsters compliance and valuation confidence.

Installers, EPCs, and developers gain from meticulous documentation and expert consultations. Early alignment positions projects for sustained profitability in an expanding market.

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