Inflation Reduction Act Apprenticeship Resources

On August 16, 2022, Public Law 117-369, 136 Stat. 1818, commonly known as the Inflation Reduction Act of 2022 (IRA), was signed into law. The IRA amended the Internal Revenue Code to add prevailing wage and Registered Apprenticeship requirements for taxpayers constructing, and in some cases performing alteration or repair, of qualified clean energy facilities, property, projects, or equipment to qualify for increased tax credit or deduction amounts. The U.S. Department of Labor’s (DOL) Office of Apprenticeship is committed to supporting the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) in the effective implementation of these apprenticeship requirements. The IRS has launched a page dedicated to providing the latest information and guidance on the implementation of the IRA.

By statute, the prevailing wage and apprenticeship requirements generally apply to qualifying facilities where construction begins 60 days or more after Treasury and the IRS publish guidance on those requirements. On November 30, 2022 Treasury and the IRS published initial guidance on the prevailing wage and apprenticeship requirements. The publication of guidance on November 30 started the 60-day period, meaning the prevailing wage and apprenticeship requirements were operative for facilities where construction began on or after January 29, 2023.

On June 25, 2024, Treasury and the IRS released a Final Rule on the prevailing wage and apprenticeship provisions of the IRA. More information about the Final Rule can be found on the IRS Website.

The IRA’s prevailing wage and apprenticeship provisions apply to the:

Alternative Fuel Refueling Property Credit
Production Tax Credit
Credit for Carbon Oxide Sequestration
Credit for Production of Clean Hydrogen
Clean Fuel Production Credit
Investment Tax Credit
Advanced Energy Project Credit
Energy Efficient Commercial Buildings Deduction

In addition, the IRA’s prevailing wage provisions apply to the:

New Energy Efficient Home Credit
Zero-Emission Nuclear Power Production Credit

High-Demand Apprenticeship Sectors

Construction

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Clean Energy

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Featured Resources

- Partner Finder Tool
  - Are you looking to join an existing program or create your own program? Our Partner Finder Tool can connect you with the right partners to help you learn more about existing programs and how to design, develop, or enhance your program.
- Occupation Finder Tool
  - Are you looking to find approved apprenticeship occupations? Our Occupation Finder Tool can help you find occupations approved for use in a Registered Apprenticeship Program along with descriptions, alternative titles, and related occupations.
- Standards Builder Tool
  - Are you looking to register an apprenticeship program? Our Standards Builder Tool can help you quickly customize and register your program in a single centralized place.
- Express Interest
  - Are you an employer or career seeker looking to learn more about Registered Apprenticeship? Learn more about Registered Apprenticeships and how you can get started as an employer or a career seeker through our Express Interest portal
- State Offices
  - Are you looking for state level assistance and support for your program? State Apprenticeship offices are located across the nation to provide technical assistance and support to program sponsors, answer questions about the apprenticeship model, guide partners on each phase of developing a program, connect business to training providers, advise partners on available funding sources to support apprenticeships, and register eligible programs.

Frequently Asked Questions

Registered Apprenticeship FAQs for the IRA

These FAQs are being provided for background information purposes only and do not constitute official IRS tax guidance. Publications in the Federal Register and Internal Revenue Bulletin represent authoritative IRS guidance. Please visit https://www.irs.gov/credits-deductions/prevailing-wage-and-apprenticeship-requirements for additional information on the prevailing wage and apprenticeship requirements.

If you have any questions that are not addressed by the following FAQs, please contact ApprenticeshipIRA@dol.gov. Interested parties are also requested to contact the Registration Agency for their state at: https://www.apprenticeship.gov/about-us/state-offices.

IRA Registered Apprenticeship Requirements FAQs

The apprenticeship requirements of the IRA include three components — a labor hours requirement, a ratio requirement, and a participation requirement. Under the labor hours requirement, the taxpayer must ensure that a minimum percentage of the total labor hours performed on the construction, alteration, or repair of a facility are performed by qualified apprentices from a registered apprenticeship program. The applicable percentage is 10% for construction beginning before 2023, 12.5% for construction beginning in 2023, and 15% for construction beginning in 2024 or after. Under the ratio requirement, the taxpayer must ensure that the applicable ratio of apprentices to journeyworkers established by the registered apprenticeship program are met for apprentices working on the facility each day. Under the participation requirement, any taxpayer, contractor, or subcontractor that employs 4 or more individuals at any time during the course of the construction, alteration, or repair of the facility must hire at least one qualified apprentice.
The apprenticeship requirements only apply with respect to construction, alteration, or repair of a facility that occurs prior to the facility being placed in service. There are no apprenticeship requirements with respect to alterations or repairs after a facility is placed in service.
Under the final regulations, apprentices must be paid at not less than the rate specified by the registered apprenticeship program for the apprentice's level of progress expressed as a percentage of the journeyworker hourly rate specified for the apprentice’s classification in the applicable wage determination.
In order to pay apprentices at wage rates less than the prevailing rates, the applicable apprentice-to-journeyworker ratio must be met for each day the apprentices perform work on the facility. Additionally, to satisfy the prevailing wage requirements, apprentices must be paid bona fide fringe benefits in accordance with the provisions of the registered apprenticeship program. If the registered apprenticeship program does not specify the payment of bona fide fringe benefits, apprentices must be paid the full amount of bona fide fringe benefits listed on the wage determination for the applicable classification in cash or in kind.
Under the Good Faith Effort Exception, taxpayers are deemed to satisfy the apprenticeship requirements if they have requested qualified apprentices from a registered apprenticeship program and either:
1. the request was denied for reasons other than the taxpayer, contractor, or subcontractor’s refusal to comply with the established standards and requirements of the registered apprenticeship program, or
2. the registered apprenticeship program failed to respond within five business days of receiving a request.
If the taxpayer, contractor, or subcontractor submits a valid, written request for apprentices to a registered apprenticeship program and the request is denied or not responded to, the taxpayer will be deemed to have exercised a Good Faith Effort with respect to the request for the period described in the request, but not exceeding 365 days (366 days in case of a leap year). The Good Faith Effort Exception only applies to the specific portion of the request for apprentices that was not responded to or was denied. The taxpayer will not be deemed to have exercised a Good Faith Effort beyond 365 days (366 days in case of a leap year) of a previously denied request unless the taxpayer submits an additional request.
Taxpayers, contractors, or subcontractors must submit a written request for qualified apprentices to at least one registered apprenticeship program which:
1. has a geographic area of operation that includes the location of the facility;
2. trains qualified apprentices in the occupation(s) needed to perform construction, alteration, or repair with respect to the facility; and
3. has a usual and customary business practice of entering into agreements with employers for placement of apprentices in the occupation for which they are training, consistent with the standards and requirements set forth in 29 CFR parts 29 and 30, and any subsequent guidance issued by the Department of Labor.
The request must be in writing and sent electronically or by registered mail. The written request must include the proposed dates of employment, occupation of qualified apprentices needed, location of the work to be performed, number of apprentices needed, the number of labor hours to be performed by the apprentices, and the name and contact information of the taxpayer, contractor, or subcontractor requesting employment of qualified apprentices from the registered apprenticeship program. Reasonable estimates are permissible.
The request must also state that the request for qualified apprentices is made with an intent to employ the qualified apprentices in the occupation for which they are being trained and in accordance with the requirements and standards of the registered apprenticeship program and to employ the qualified apprentices consistent with the number of hours and dates of employment specified in the request. If the employer of the requested qualified apprentices is not the same as the taxpayer, contractor, or subcontractor submitting the request for qualified apprentices, then the request must include the name of the employer.
The Initial request to a registered apprenticeship program for qualified apprentices must be made no later than 45 days before the qualified apprentices are requested to start work. Any subsequent requests for qualified apprentices made to the same registered apprenticeship program after the initial request must be made no later than 14 days before the qualified apprentices are requested to start work.
In order to satisfy the Good Faith Effort Exception, taxpayers, contractors, or subcontractors need to submit a request for qualified apprentice to at least one registered apprenticeship program. While it may be possible for a taxpayer to satisfy all the apprenticeship requirements from one apprenticeship program, it is likely that given the multiple occupations involved in the construction, alteration, or repair of a facility, a taxpayer, contractor, or subcontractor will need to request apprentices from more than one apprenticeship program. This is in part because a registered apprenticeship program typically trains apprentices in a single occupation, whereas more than one occupation will be needed to meet the apprenticeship requirements.
If there is no registered apprenticeship program with a geographic area of operation that includes the location of the facility, taxpayers may be deemed to satisfy the Good Faith Effort Exception for the apprentices they (or the contractor or subcontractor) would have requested for that occupation. A taxpayer, contractor, or subcontractor that cannot locate a registered apprenticeship program with an area of operation that includes the location of the facility should consider contacting the DOL’s Office of Apprenticeship or relevant State apprenticeship agency for assistance in locating a program.
If the taxpayer, contractor, or subcontractor submits a request as described above and the request is denied or not responded to, the taxpayer will be deemed to have exercised a Good Faith Effort with respect to the request for a period described in the request but not exceeding 365 days (366 days in case of a leap year) from the date of the request. The taxpayer will not be deemed to have exercised a Good Faith Effort beyond 365 days (366 days in case of a leap year) of a previously denied request unless the taxpayer submits an additional request.
There is no limit on the number of requests a taxpayer, contractor, or subcontractor may submit to one or more registered apprenticeship programs for purposes of being deemed to have exercised a Good Faith Effort. Additionally, a taxpayer, contractor, or subcontractor is not required to make subsequent requests to the same registered apprenticeship program in order to qualify for the Good Faith Effort Exception.
If the registered apprenticeship program fails to respond to a valid request within five business days after the date on which such registered apprenticeship program received the taxpayer’s (or its contractor or subcontractor) request, then such request is deemed to be denied. A valid response to a request for qualified apprentices is a substantive written reply that agrees, in part or in whole, to the specific requirements in the request.
A registered apprenticeship program’s response that it can partially fulfill the request in the occupation(s) for which it trains qualified apprentices does not constitute a denial of the request with respect to the parts of the request that can be fulfilled. The parts of the request that were denied because they cannot be fulfilled will qualify a taxpayer for the Good Faith Effort Exception with respect to the portion of the request which was denied if the taxpayer, contractor, or subcontractor accepts the requested apprentices that can be fulfilled and the other requirements for the Good Faith Effort exception have been met.

General Questions about Prevailing Wage and Apprenticeship Requirements

Yes, there are two statutory provisions that provide for increased credit or deduction amounts without satisfying the prevailing wage and apprenticeship requirements. They are the one-megawatt exception and the beginning of construction exception.
- Under the one megawatt exception in section 45 a qualified facility that has a maximum net output of less than one megawatt of (as measured in alternating current) is eligible for the increased credit amount without satisfying the prevailing wage and apprenticeship requirements. Similar exceptions apply for a qualified facility with a maximum net output of less than one megawatt (as measured in alternating current) under sections 45Y and 48E, an energy project with a maximum net output of less than one megawatt of electrical (as measured in alternating current) or thermal energy under section 48, and energy storage technology with a capacity of less than one megawatt under section 48E.
- Under the beginning of construction exception for the credits under sections 30C, 45, 45Q, 45V, 45Y, 48, 48E, and the deduction under 179D, a taxpayer that begins construction or installation of a facility before January 29, 2023, may be eligible for the increased credit or deduction amount without needing to satisfy the prevailing wage and apprenticeship requirements
Taxpayers are required to maintain and preserve sufficient records to establish compliance with the prevailing wage requirements. These records include payroll records for each laborer or mechanic (including each qualified apprentice) employed by the taxpayer, contractor, or subcontractor that reflect the hours worked in each classification and the actual wages and fringe benefits paid to each laborer and mechanic performing construction, alteration, or repair of the facility. In addition to payroll records otherwise maintained by the taxpayer, records sufficient to demonstrate compliance may include, but are not limited to, identifying information (including addresses, telephone numbers, and email addresses) for laborers and mechanics, the location and type of facility, the labor classification(s) applied to each laborer and mechanic, the applicable wage determination(s), copies of executed contracts for construction, alteration, or repair with any contractor or subcontractor, and records to support contributions to bona fide fringe benefit programs. If work is done pursuant to a qualifying project labor agreement, the taxpayer must also maintain and preserve records related to that qualifying project labor agreement. Taxpayers are also required to maintain records of any correction payments made to any laborer or mechanic.
Taxpayers are also required to maintain and preserve records to establish compliance with the apprenticeship requirements. These records may include copies of any written requests for apprentices by the taxpayer, contractor, or subcontractor, any agreement entered by the taxpayer (or contractor or subcontractor) with a registered apprenticeship program, records reflecting the required ratio of apprentices to journeyworkers prescribed by each registered apprenticeship program from which qualified apprentices are employed, and records reflecting the daily ratio of apprentices to journeyworkers.
The IRA Registered Apprenticeship requirements FAQs have been republished on this webpage for the reader's convenience. For the official version of this FAQ, as well additional FAQs on “penalty and cure provisions and recordkeeping,” please see the IRS FAQs..
For all other IRS FAQs on IRA prevailing wage requirements, see Frequently asked questions about the prevailing wage and apprenticeship under the Inflation Reduction Act.

Registered Apprenticeship General Information FAQs

A Registered Apprenticeship program is an apprenticeship program registered under the National Apprenticeship Act that meets the requirements of 29 CFR parts 29 and 30.
A Registered Apprenticeship program is an industry-driven, high-quality career pathway where employers can develop and prepare their future workforce, and individuals can obtain paid work experience, receive progressive wage increases, classroom instruction, and a portable, nationally-recognized credential. Registered Apprenticeship programs are industry-vetted and approved by the U.S. Department of Labor or a State Apprenticeship Agency. For more information on Registered Apprenticeship programs, please visit: https://www.apprenticeship.gov/employers/registered-apprenticeship-program.
A State Apprenticeship Agency (SAA) is an agency of a State government that has been recognized by the Office of Apprenticeship (OA) as a Registration Agency to register apprenticeship programs in that State, and has responsibility and accountability for overseeing apprenticeship within the State, including compliance with 29 CFR parts 29 and 30. A map showing which state agencies have been recognized by OA as SAAs, along with state agency contact information, is available at https://www.apprenticeship.gov/about-us/apprenticeship-system.
Registered Apprenticeship program regulations at 29 CFR 29.5(b)(7) require: “A numeric ratio of apprentices to journeyworkers consistent with proper supervision, training, safety, and continuity of employment, and applicable provisions in collective bargaining agreements, except where such ratios are expressly prohibited by the collective bargaining agreements. The ratio language must be specific and clearly described as to its application to the job site, workforce, department or plant.”
Apprentice to journeyworker ratios are established in the standards developed by Registered Apprenticeship program sponsors, in accordance with the requirements of the U.S. Department of Labor’s Office of Apprenticeship (OA) or an applicable State Apprenticeship Agency (SAA). Apprentice to journeyworker ratios in Registered Apprenticeship programs are subject to the approval by OA or an SAA consistent with 29 CFR 29.5, and any applicable subregulatory guidance. In states where OA registers apprenticeship programs, the approval of a program’s apprentice to journeyworker ratios must follow the subregulatory guidance contained in Circular 2021-02 (which can be accessed from this link: https://www.apprenticeship.gov/about-us/legislation-regulations-guidance/circulars). SAAs may have their own policies regarding the approval of program ratios, consistent with 29 CFR 29.5.
Registered Apprenticeship programs are available in occupations that have been approved by the Office of Apprenticeship (OA) as “apprenticeable occupations” (see 29 CFR 29.4). Occupations approved for apprenticeship can be found on OA’s occupation finder at https://www.apprenticeship.gov/apprenticeship-occupations.
Many occupations approved for Registered Apprenticeship programs are within the meaning of "construction, alteration, or repair" work covered by the IRA increased tax benefits. “Construction, alteration, or repair” means all types of work done on the facility by laborers and mechanics of the taxpayer, a construction contractor or construction subcontractor, including altering, remodeling, and installation; painting and decorating; the manufacturing or furnishing of materials, articles, supplies or equipment on the site of the facility; and transportation between the taxpayer’s facility and an off-site facility dedicated to the construction of the taxpayer’s facility and deemed part of the site of the work under 29 CFR 5.2(l). For example, using the occupation finder tool and browsing by "construction" industry yields over 50 occupations (and associated O*Net Codes) approved for Registered Apprenticeship programs. Browsing by "manufacturing," "transportation and warehousing," and "utilities" industries leads to additional or overlapping results for occupations in the clean energy sector. A list of all occupations approved by OA is available for download on the occupation finder site: https://www.apprenticeship.gov/sites/default/files/wps/apprenticeship-occupations.xlsx.
Employers seeking to join Registered Apprenticeship programs for the purpose of hiring qualified apprentices may do so by first identifying group registered apprenticeship programs in the needed occupations and geographic area. The Office of Apprenticeship’s partner finder tool, available at https://www.apprenticeship.gov/partner-finder, allows employers to search for group Registered Apprenticeship programs by occupations and state. State Apprenticeship Agencies may have additional resources for identifying group Registered Apprenticeship programs.
Group Registered Apprenticeship programs are programs in which multiple employers participate in employing apprentices (as opposed to an individual apprenticeship program that only places apprentices with one specific employer). To request an apprentice from such a program, the employer must agree to the standards and requirements of the Registered Apprenticeship program; this is customarily done through an agreement (an employer acceptance agreement or being a signatory to the Registered Apprenticeship Program’s collective bargaining agreement or project labor agreement). Once an employer has joined a Registered Apprenticeship program via the customary agreement, the employer may request apprentices through the Registered Apprenticeship program’s usual processes.
Employers may sponsor their own Registered Apprenticeship programs and hire their own “qualified apprentices” by registering their new programs with the appropriate Registration Agency, the Office of Apprenticeship (OA) or their State Apprenticeship Agency (SAA). Determining whether to register with OA or an SAA depends on the state the sponsor chooses to register and operate their program. OA has many resources available for potential sponsors on apprenticeship.gov.
- To locate and contact the appropriate Registration Agency, please visit https://www.apprenticeship.gov/about-us/state-offices.
  - For information about registering a new apprenticeship program, please visit https://www.apprenticeship.gov/employers/registered-apprenticeship-program; employers are encouraged to utilize OA’s “Express Interest” page - https://www.apprenticeship.gov/employers/express-interest-instructions.
- To assist in developing standards of apprenticeship, please visit OA’s “Standards Builder” page - https://www.apprenticeship.gov/employers/registered-apprenticeship-program/register/standards-builder