Documenting risk

PV projects rarely fail because of vision, permitting or demand issues. They fail because of missing proof. Documentation gaps are becoming a key source of financing and execution risk. Intertek CEA Chief operating officer Jeffrey Burkett sees a clear pattern across the market: technically sound and commercially viable projects are still unable to close financing. Not due to fundamental flaws, but because critical documentation was not built up along the way.

A lender asks for supply chain traceability. A tax equity provider requires module-level quality validation beyond a surface audit. A local authority requests a defined decommissioning plan. But these vital project steps were never formalized. These are failures that appear at the financing table, not in the field. And they are entirely avoidable.

For the better part of the last decade, the Investment Tax Credit (ITC) has acted as a cushion for solar projects in the United States. It allowed the market to prioritize speed, absorb inefficiencies, and still close deals. As that era comes to an end, the next phase of solar will reward discipline over momentum.

There are three areas where this documentation gap consistently emerges: supply chain traceability, module quality assurance, and end-of-life planning. None of these are new risks, what has changed is the consequence of getting them wrong. Developers who continue to treat these as secondary considerations will face a shrinking pool of counterparties willing to carry that risk.

Supply chain traceability

With globalized manufacturing and increasing regulatory scrutiny, a module’s origin now impacts tax credit eligibility, tariff exposure, and the risk of import detention. When documentation cannot substantiate origin, financing timelines slip or stop entirely.

Developers pursuing domestic content incentives must validate upstream components with auditable precision. Those managing import risk must go further, building traceability systems that stand up to lender and regulatory scrutiny.

Overreliance on a single supplier has become a structural vulnerability. Leading developers are now qualifying multiple suppliers across key components. Resilience is no longer optional.

Audit to evidence

Margin compression in global manufacturing, combined with rapid capacity expansion in the US and other regions, has brought variability that surface-level audits cannot detect. We see elevated defect rates at the factory and in-field that only emerge under deeper inspection.

Lenders are responding accordingly. Expectations have shifted toward measurable, enforceable quality thresholds typically requiring pre-shipment defect rates at or below 1.5%.

What enforces this is contract structure. Best-in-class developers are embedding detailed technical exhibits into procurement agreements – locking bills of materials, defining inspection protocols, mandating factory access, and extending oversight from production through installation.

Automated electroluminescence analysis and high-throughput field inspection systems now enable full-scale verification at speed, removing the tradeoff between rigor and timeline. The implication is clear: if quality is not evidenced, it will be questioned – and that question will surface during financing.

End-of-life planning

Decommissioning has become a front-end requirement. Regulatory frameworks are tightening. Landowners, lenders, and offtakers increasingly expect defined, costed, and verifiable end-of-life strategies before committing capital.

The financial exposure is material. Industry estimates place decommissioning costs at approximately $50,000/MW to $150,000/MW, depending on site conditions. Without a documented plan, that liability becomes a barrier to closing.

Beyond removal, accountability is extending to recycling and material traceability. While regulation has yet to fully standardize this, investor expectations already have. Developers who establish credible pathways today will differentiate themselves in a capital-constrained market.

Closing the gap

None of these disciplines are new. What is new is their role in determining who gets financed and who does not.

The ITC created flexibility and allowed the industry to move fast, sometimes at the expense of rigor. That flexibility is narrowing. The developers who lead the next phase will be those who build with evidence, structure, and accountability from the outset.

In a market with less room for error, bankability is no longer assumed. Increasingly, the evidence trail is the competitive advantage.

About the author

Jeffrey Burkett is chief operating officer at Intertek CEA, where he leads the company’s operations, spanning supply chain, quality assurance, engineering, and market intelligence, while actively exploring and pursuing new market opportunities. He has more than 30 years of in-depth engineering, procurement, and construction expertise across solar, energy storage, water, and electric vehicle technologies.

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