Old REAP vs. new REAP: what changed in 2026
Last updated . Reflects USDA's October 1, 2026 final rule.
The biggest change is timing. You now build the project first and apply 12 to 24 months after it is finished. (7 CFR §4280.122(a)(1)) The new rule also limits who can apply, bans some projects outright, and replaces state competitions with one national ranking. (7 CFR §4280.120(a)(6); §4280.122(b); §4280.150(b))
USDA published the new rule on October 1, 2026. It takes effect October 16, 2026, and USDA is taking comments through November 2, 2026 (rule discussion, Federal Register 2026-20178). For the full overview, see our guide to the 2026 REAP final rule.
How we built this comparison
The "before" column uses only what USDA's own rule document says about the old rule. Topics where the rule document does not describe the old rule are left out. We did not fill gaps from memory. The "under the 2026 rule" column cites the new regulation, 7 CFR part 4280, subpart B.
Side-by-side comparison
| Topic | Before the 2026 rule | Under the 2026 rule |
|---|---|---|
| When you apply | Applicants applied before building. USDA says many started their projects as soon as it told them a complete application had been received. Application information was based on project estimates and expectations. (rule discussion, Federal Register 2026-20178) | The project must be completed 12 to 24 months before you apply. (7 CFR §4280.122(a)(1)) For the first application window only, the project period can have ended 12 to 36 months before you apply. (7 CFR §4280.122(a)(6)) |
| Energy data | Estimates at application, then two or three years of annual outcome reports after the award. (rule discussion, Federal Register 2026-20178) | Renewable systems: 12 consecutive months of energy use before installation and 12 months of energy produced after. Efficiency projects: energy use before and after, as documented in the energy assessment or audit. (7 CFR §4280.131(b)(17)(i)) |
| Ownership rules for agricultural producers | USDA says the definition was revised to align more closely with the one in 7 CFR part 4284, subparts J and K. (rule discussion, Federal Register 2026-20178) | The business must be 100% owned by one individual, or by an individual and their immediate family, or wholly owned by an Indian Tribe. All owners must take part in day-to-day labor, management, or field operations. The majority owner must earn at least 50% of their income from the farming operation. (7 CFR §4280.104 (Agricultural producer)) |
| Highest-level owner | USDA calls this a clarification. The rule document does not describe the old wording. (rule discussion, Federal Register 2026-20178) | The applicant must be the Highest-Level Owner, meaning no other entity owns or controls it, or be wholly owned by an Indian Tribe. (7 CFR §4280.104; §4280.120(a)(6)) |
| Applications per year | One renewable energy application and one energy efficiency application per federal fiscal year. (rule discussion, Federal Register 2026-20178) | One application per federal fiscal year from each Highest-Level Owner and the entities owned by its individual owners. (7 CFR §4280.133(c)) One award per year on the same basis. (7 CFR §4280.120(a)(8)) |
| Ground-mount solar or wind on cropland | USDA describes the cropland ban as a new change. (rule discussion, Federal Register 2026-20178) | Not eligible. (7 CFR §4280.122(b)(11)) Retrofits of any existing ground-mount solar or wind system, or any solar or wind system on cropland, are also not eligible. (7 CFR §4280.122(b)(7)) |
| Foreign components | USDA describes the foreign-adversary ban and the country-of-origin question as new. (rule discussion, Federal Register 2026-20178) | Solar PV and wind systems with any component made in a country listed as a foreign adversary in 15 CFR 791.4 are not eligible. Projects installed before the rule's publication date are exempt. (7 CFR §4280.122(b)(19)) You must list the country of origin of every system component. (7 CFR §4280.131(b)(5)) |
| Multiple locations | Projects at more than one location could apply. USDA says they are "no longer eligible." (rule discussion, Federal Register 2026-20178) | Not eligible. One project, one location. (7 CFR §4280.122(b)(10)) |
| Batteries and other storage | USDA describes the storage size limit as a change to encourage right-sized systems. (rule discussion, Federal Register 2026-20178) | With storage, the system's yearly production is capped at 120% of your energy use in the 12 months before installation. Storage cannot be larger than the system it is paired with. (7 CFR §4280.122(a)(19)) Adding storage to an existing system, or stand-alone storage, is not eligible. (7 CFR §4280.122(b)(18)) |
| EV chargers | The ban on equipment that dispenses energy at retail was in the old rule's definitions section. The rule document says nothing more about chargers under the old rule. (rule discussion, Federal Register 2026-20178) | Projects that dispense energy at retail are not eligible. (7 CFR §4280.122(b)(15)) USDA names electric vehicle chargers and charging stations as examples, and says EV chargers are not eligible (rule discussion, Federal Register 2026-20178). Vehicles are an unallowable cost. (7 CFR §4280.125(b)(5)) |
| Grant size | Separate minimum amounts for renewable and efficiency grants. The rule document does not give the old amounts. (rule discussion, Federal Register 2026-20178) | Minimum request of $1,500 for both. Maximum of $500,000 for renewable systems and $250,000 for efficiency. (7 CFR §4280.122(a)(2)) You must cover at least 75% of project cost. (7 CFR §4280.122(a)(3)) |
| Scoring and competition | Multiple state and national competitions. USDA says the scoring criteria were revised to remove duplication, but the rule document does not list the old criteria. (rule discussion, Federal Register 2026-20178) | 90 points plus up to 10 priority points. (7 CFR §4280.140(d)-(e)) A reserved-funds competition for requests of $20,000 or less, then one national competition. The top-scoring application from each state is funded first, then the rest in rank order. No application below 40 points is funded. (7 CFR §4280.150(a)-(b)) |
| Application review | Technical merit review, with technical report appendices that varied by project cost. USDA notified applicants when their application was found eligible. (rule discussion, Federal Register 2026-20178) | Applications are checked for completeness, eligibility, risk, and merit. (7 CFR §4280.140) Everything must come in one application, and incomplete applications are rejected. (7 CFR §4280.133(b)) USDA will no longer notify applicants at the eligibility stage (rule discussion, Federal Register 2026-20178). |
Timing: you build first, then apply
Under the new rule, the project period starts when you incur the first allowable cost. It can last no more than 24 months, and it ends no later than 30 days after the system is installed. (7 CFR §4280.122(a)(6)) That end date must fall 12 to 24 months before you apply. (7 CFR §4280.122(a)(6))
USDA gave several reasons. Applicants were often confused about which costs they could charge to the award. Many proposed systems were oversized. Actual data lets USDA judge projects more accurately (rule discussion, Federal Register 2026-20178). USDA also points to the REAP guaranteed loan program, 7 CFR 5001, as a way to cover up-front costs (rule discussion, Federal Register 2026-20178). See our project financing page.
If your application was pending when USDA stopped processing applications on March 31, 2026, USDA says the new structure lets you resubmit, as long as you meet the new requirements (rule discussion, Federal Register 2026-20178). Check whether the first window is open on our REAP status page.
Who can apply
Agricultural producers and rural small businesses remain eligible, but they must now be Highest-Level Owners (rule discussion, Federal Register 2026-20178). A farm counts as an agricultural producer only if it meets one of the ownership structures in the new definition. (7 CFR §4280.104 (Agricultural producer)) A rural small business must have an active SBA profile in SAM.gov and show up as a small business in the Small Business Search. (7 CFR §4280.120(a)(2)) Every applicant must have been an existing business for at least 12 months before the project period started. (7 CFR §4280.120(a)(5))
Read more in our guides to the Highest-Level Owner rule and who qualifies.
Projects that are now off the table
- Ground-mount solar PV or wind on cropland. (7 CFR §4280.122(b)(11)) Cropland has the meaning in 7 CFR 718.2, the Farm Service Agency's definition. (7 CFR §4280.104) See our cropland rule guide.
- Ground-mount solar or wind systems that cannot document matching historical energy use. (7 CFR §4280.122(b)(13))
- Solar PV or wind with components from a foreign-adversary country, unless installed before the rule's publication date. (7 CFR §4280.122(b)(19)) See our foreign adversary guide.
- Projects at more than one location. (7 CFR §4280.122(b)(10))
- Adding storage to an existing system, and stand-alone storage. (7 CFR §4280.122(b)(18))
- Projects that dispense energy at retail. (7 CFR §4280.122(b)(15))
- Energy efficiency work on new building construction. USDA removed that option (rule discussion, Federal Register 2026-20178). Efficiency projects must now improve existing buildings, equipment, or an existing renewable system. (7 CFR §4280.122(a)(1)(ii))
Smaller changes worth knowing
- Meters. The old rule allowed meters shared with a residence. That provision was removed (rule discussion, Federal Register 2026-20178). The project now needs its own dedicated meter. (7 CFR §4280.122(a)(16))
- Rural location. USDA amended rural area eligibility so the project must be located in a rural area (rule discussion, Federal Register 2026-20178). (7 CFR §4280.122(a)(4)) The rule document does not quote the old wording. To check an address, use the USDA eligibility map.
- Payback. Simple payback must be equal to or less than the useful life of the system. (7 CFR §4280.122(a)(18))
- Financial statements. All applicants must provide business-level financial statements. Projects costing $200,000 or more also need two years of pro forma statements. (7 CFR §4280.131(a)(9))
- Reports after the award. Semi-annual reports, the final project development report, and Form RD 4280-3D are no longer required (rule discussion, Federal Register 2026-20178). A final financial report and a final performance report are due 120 calendar days after award approval. (7 CFR §4280.160(a)-(b))
- Insurance. The insurance coverage the old rule required is no longer required (rule discussion, Federal Register 2026-20178).
For point details, see how REAP is scored or estimate your score. For grant limits, see our grant amounts guide.
What the rule does not settle
The priority points, worth up to 10, will be posted on the program website. They are not in the rule. (7 CFR §4280.140(e)) Instructions on how and where to submit will come in an annual notification. (7 CFR §4280.133(b)) If your project falls in a gray area, confirm with your State Energy Coordinator.
If you want help sorting out where your project stands under the new rule, CGF can help. Or start with the eligibility tool.
Related guides
- The 2026 REAP final rule, explained
- The REAP cropland rule
- The Highest-Level Owner requirement
- REAP grant amounts under the new rule
This page summarizes the USDA final rule, Federal Register 2026-20178 (Oct. 1, 2026). It is not legal advice. The rule is a final rule with a comment period, so USDA may change it. USDAREAPGrant.com is an independent website operated by Cleaner Greener Future LLC. It is not USDA. For official information, see USDA Rural Development or your State Energy Coordinator.
See where your project stands under the new rule
Answer a few questions about your business and project. You will see right away whether it fits the 2026 REAP rules.