IRS Forms

Form 8933 Schedule B – Operator Certification for 45Q Storage

Step by step guide for disposal operators to complete Form 8933 Schedule B, align with EPA MRV, include registration numbers, and support accurate 45Q claims.

Accountably Editorial Team 10 min read Nov 14, 2025 Updated Nov 14, 2025
I remember the first time a client’s file landed on my desk with missing EPA MRV details. The tax team had done solid work, but because the operator’s certification was thin, the return went into limbo. We fixed it, but it taught me a simple truth. With section 45Q, you win or lose on delivery.

If you are the disposal site operator or a designated operator, Schedule B is your proof of the injections that another taxpayer will use to claim the credit. It is not optional. It is the backbone of the claim.

Key takeaways

  • Schedule B is the operator’s certification for injections into secure geological storage, and it must align with the owner’s Form 8933 package and other schedules, especially A and D when recapture applies.
  • Operators provide owner details, site and operator identifiers, EPA MRV references, registration numbers, and the metric tons delivered and stored for the year. You also attest that Schedule B matches EPA filings.
  • For 2025, if you or the owner use the pre‑2018 election under section 45Q(b)(3), the inflation‑adjusted credit amounts are 28.43 per ton for disposal and 14.21 per ton for EOR or utilization. These apply only to that election.
  • Post‑IRA projects can qualify for higher credit values when prevailing wage and apprenticeship rules are met, for example 85 per ton for disposal and 60 per ton for EOR for non‑DAC projects, with 180 and 130 for DAC. These amounts are statutory and separate from the b(3) election mechanics.
  • If you plan to use elective payment or transfer, complete pre‑filing registration in IRS Energy Credits Online and include the registration number with the return.

When Schedule B is clean, the return moves. When Schedule B is messy, everything stalls.

What Schedule B does, and why it matters

Schedule B, Disposal Operator Certification, is how you, as the disposal site operator or designated operator, confirm the qualified carbon oxide that was injected into secure geological storage during the tax year. The owner relies on your certification to support the credit. The IRS expects your Schedule B to mirror EPA reporting, and owners must use your numbers when completing Schedule A. Provide a copy of Schedule B to each owner of the geological disposal site.

Schedule B is used only for geological disposal. If the injections are for EOR, the operator uses Schedule C instead. Recapture events are reported on Schedule D and flow through to Form 8933 and Form 4255 for the recapture math.

Who must file Schedule B

You must file Schedule B if you are the operator or designated operator of a geological disposal site at which captured qualified carbon oxide was injected during the year. This schedule travels with the Form 8933 package and is shared with each owner of the disposal site. Do not use Schedule B for EOR volumes, since the EOR operator uses Schedule C for those injections.

How this ties to Form 8933

Form 8933 is where the credit is claimed. Schedules A through F are the supporting certifications. The owner’s Schedule A picks up the amounts from the operator’s Schedule B line items, so your file names, IDs, and EPA references must line up. If there is a recapture event later, the operator or owner reports it on Schedule D, and the recapture amount is entered on Form 8933, then ultimately on Form 4255.

Key definitions and scope

Term Scope
Qualified carbon oxide Measure only contained CO2 weight, in metric tons, consistent with EPA and IRS rules
Operator or designated operator Party operating the geological disposal site for the period reported
Secure geological storage Storage that meets IRS and EPA standards and MRV requirements under subpart RR where applicable
Certification/attestation Operator attests Schedule B conforms to EPA filings and MRV plan and is included in the Form 8933 package

These definitions map directly to the Instructions for Form 8933 and Schedule B. The operator’s role is to certify accurate, supportable injections that match the owner’s filing.

Your north star is consistency. If your Schedule B cannot be reconciled to EPA filings and the owner’s Schedule A, the return slows down or gets questioned.

Exactly what Schedule B asks you to provide

Schedule B is short, but it is precise. Here is what the form requires, based on the current IRS PDF.

  • Owners of the geological disposal site, including names, addresses, EINs, and operating interest percentages. If there are more than four owners, attach a separate schedule.
  • Site details, including the name and location, the operator’s name and EIN, any other entity identified as operator for other purposes, and the nature of those purposes.
  • IRS registration number(s) for the geological disposal facility and, if available, the site’s EPA e‑GGRT ID.
  • The month and year injections began, a checkbox attestation that stored carbon oxide figures are consistent with EPA subpart RR filings and the applicable MRV plan, and either attach the MRV plan or provide the URL where it can be viewed on EPA’s site.
  • Supplier details for all qualified carbon oxide, including supplier name, EIN, capture facility location, IRS registration number for the capture facility, and EPA e‑GGRT ID if any. You must indicate if a supplier provided any nonqualified CO2.
  • Disposal metrics, by owner and supplier, showing metric tons delivered and metric tons stored. You will total qualified suppliers and then total all suppliers to show grand totals delivered and stored. A final checkbox attests that this information conforms to all applicable EPA filings.

The form is only two pages, but it does heavy lifting by tying your attested tons to EPA MRV documentation and e‑GGRT reporting.

Facility, equipment, and placed‑in‑service dates

Placed‑in‑service data for capture equipment lives in Form 8933 Part I. It drives credit eligibility, rate selection, and the interaction with the pre‑2018 election. When you complete Schedule B, make sure your site and registration identifiers align with Part I, so the owner can correctly calculate the credit for the right vintage and pathway.

  • Confirm the facility description and any IRS registration number on Form 8933 Part I match what you include on Schedule B.
  • If injections relate to pre‑February 9, 2018 capacity, the owner may be using the section 45Q(b)(3) framework. In that case, your totals must be tagged correctly so the credit math matches the elected rules.

Reporting injections at geological disposal sites

Your job on Schedule B is to report carbon oxide delivered and stored, by owner and by qualified supplier, for the tax year, and to attest that the information matches EPA filings and the MRV plan. The EPA tie‑out is explicit on the form with a checkbox, e‑GGRT IDs, and an MRV attachment or URL. This is where many files stumble when the MRV link is outdated or the totals do not reconcile. Build a quick pre‑filing check to confirm those links and totals.

Operator responsibilities that reduce review friction

  • Keep a single source of truth for owner percentages and EINs.
  • Maintain a supplier roster with registration numbers and e‑GGRT IDs.
  • Reconcile delivered versus stored tons and explain any variance.
  • Confirm that the MRV plan on file is the current approved version and that the EPA submission period matches the tax year.

If you are wondering what the IRS looks for first, assume they check that your Schedule B totals, EPA MRV numbers, and the owner’s Schedule A agree to the unit.

Documentation for secure geological storage

To prove secure storage, keep a record set that shows the trail from capture to injection to long‑term containment. At a minimum, retain injection logs, well identifiers, pressure data, and supporting geologic documentation plus the MRV plan and EPA filings that your Schedule B references. Your file should also include chain‑of‑custody records from the capture facility through to the site. These recordkeeping expectations are built into the overall Form 8933 instructions and the design of Schedule B.

Measurement and verification of metric tons

Measure only contained CO2, and be ready to prove it. The IRS expects amounts to be measured at the source of capture and verified at the point of disposal or injection. In practice, you will rely on calibrated flow meters, composition analyses, and reconciliation workpapers. If the verified amount differs from the captured amount, the IRS presumes the lesser controls unless you can establish that the greater amount is correct. Keep calibration certificates, sampling plans, lab reports, and mass‑balance or metering worksheets.

A clean metering and sampling file is your best defense. If someone else had to pick up your worksheet tomorrow, could they recalculate the tons and arrive at the same number within minutes?

EPA alignment matters

Schedule B bakes in the EPA connection with e‑GGRT IDs, MRV plan references, and explicit attestations that your storage figures match EPA filings. Before you sign off, open your EPA submissions and confirm that the totals, dates, and site identifiers match what you are about to file.

How Schedule B interacts with Schedules A, C, D, and E

  • Schedule A, owner certification. Owners of the geological disposal site report amounts from your Schedule B on their Schedule A. Your accuracy controls their accuracy.
  • Schedule C, EOR operator certification. If the injections are for EOR, the EOR operator files Schedule C instead of Schedule B for those volumes.
  • Schedule D, recapture. If a recapture event occurs, the operator or owner reports it on Schedule D. The recapture amount then flows to Form 8933, Part III, line 7, and to Form 4255 to compute the tax impact. Keep your Schedule B history handy because the IRS expects dates and tonnage to tie out.
  • Schedule E, election certification. If the capture facility owner elects to pass the credit under section 45Q(f)(3)(B), that election does not replace your operator reporting. You still complete Schedule B for geological disposal volumes.

Timing rules and placed‑in‑service dates

Placed‑in‑service dates for the capture equipment drive which rate framework the owner uses. Your Schedule B must line up with the Form 8933 Part I data that sets those rules. For pre‑February 9, 2018 capacity, owners may rely on the section 45Q(b)(3) election. For post‑2018 and especially post‑2022 projects, the IRA amounts and prevailing wage and apprenticeship rules matter. Tag your totals to the right vintage so the credit calculation is defensible.

Recapture timing

If a recapture event happens in a later year, Schedule D ties the recapture back to the original reported injections. The amount is reported on Form 8933 and calculated on Form 4255. Keep contemporaneous records so you can show exactly which injections are affected.

Rates and elections you must know for 2025

Two parallel frameworks often get confused.

  • Section 45Q(b)(3) election for pre‑2018. For calendar year 2025, the inflation‑adjusted rates are 28.43 per ton for disposal and 14.21 per ton for EOR or utilization. These apply only when a taxpayer makes the b(3) election to use the statutory amounts under 45Q(a)(1) or (2) as adjusted for inflation.
  • Post‑IRA amounts for property placed in service after 2022. Base amounts are 17 and 12 per ton, but when prevailing wage and apprenticeship are satisfied, the amounts increase to 85 and 60, and for DAC to 180 and 130 per ton. These are the headline values most projects target. They are separate from the b(3) election amounts.

Quick rule of thumb, confirm whether the owner is applying the b(3) election for pre‑2018 capacity or the IRA framework for post‑2022 equipment. Your Schedule B totals must match the election in play.

Pre‑filing registration, elective payment, and transfer

If the owner plans to make an elective payment election or transfer the credit, the entity must complete pre‑filing registration in Energy Credits Online, obtain a registration number for each credit property, and include those numbers with the return. As of November 11, 2025, the IRS has 2025 registration open. Allow time for review and register at least 120 days before the return due date, including extensions.

Operator’s role in elective pay or transfer

  • Confirm the registration number included on Form 8933 matches the site and capture facility identifiers you report on Schedule B.
  • Keep the registration confirmation with your Schedule B documentation.
  • For transfers, ensure the portion transferred ties to the metric tons you certified, and that cash consideration and ownership records are in the file.

Recordkeeping that passes review

Build a Schedule B package and store it with your Form 8933 files.

  • Injection evidence. Metering data, transfer tickets, well logs, and a reconciliation to Schedule B totals for the year.
  • Authority. Operator agreements or designation letters and coordination notes with owners.
  • MRV and EPA filings. Approved MRV plan or URL, e‑GGRT IDs, and proof that EPA totals match Schedule B.
  • Recapture. Any remediation or correspondence, tied to the original injections and reflected on Schedule D and Form 4255 if triggered.

Aim for a package that a new reviewer can understand in ten minutes. If you cannot follow it cold, an examiner will struggle too.

FAQs

Who needs to file Schedule B?

The operator or designated operator of a geological disposal site that injected qualified carbon oxide during the year files Schedule B. Provide owner and site identifiers, supplier details, registration numbers, and attested tons delivered and stored. Share a copy with each owner.

Where do I find the latest Schedule B?

Download the current Schedule B PDF from the IRS Form 8933 page. Check the page’s “Recent developments” and link to “Schedule B (Form 8933) PDF.” Use the December 2024 version until the IRS posts an update.

Do I sign Schedule B under penalties of perjury?

Schedule B includes operator attestations and ties into a signed Form 8933 package that is filed under penalties of perjury. Keep your attestation and supporting documents consistent with EPA filings and your MRV plan.

What if I miss Schedule B or the MRV attachment?

You risk processing delays, disallowance of elections, or adjustments to claimed credits, and you may face recapture complications later. The fix is better controls on registration numbers, EPA tie‑outs, and recordkeeping.

Practical close and next steps

If you run an accounting firm or operate a geological disposal site, your bottleneck usually is not clients, it is delivery. Schedule B is a good litmus test. When your operators, reviewers, and owners use the same IDs, MRV links, and totals, returns move cleanly. If you want help building the disciplined workflow to keep this tight, Accountably focuses on controlled offshore delivery, which includes SOPs for IRS registration numbers, EPA MRV tie‑outs, and schedule‑to‑schedule reconciliations. Use us where it makes sense, and keep the credit compliance owned by your team.

Compliance note, rates, rules, and forms cited here reflect IRS pages reviewed through November 11, 2025. Always confirm the current Form 8933 instructions, Schedule B PDF, 45Q(b)(3) inflation amounts for the year of claim, and the status of Energy Credits Online registration for your filing period.

Key sources used in this guide

  • About Form 8933 and schedules, operators vs owners, and links to current PDFs.
  • Instructions for Form 8933, including schedules, measurement and verification, recapture, and statements.
  • Schedule B PDF, including owner, operator, MRV, e‑GGRT, supplier, and metric‑ton attestations.
  • 2025 inflation‑adjusted 45Q(b)(3) amounts.
  • Pre‑filing registration for elective pay or transfer, Energy Credits Online.
  • Post‑IRA 45Q amounts and PWA framework.

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