If you allow someone else to claim your credit, or you receive a pass‑through, you document that on Schedule E. The IRS made this explicit in its December 2024 instructions.
Key Takeaways
- Schedule F now means Utilization Certification. Use it when you claim credits for qualified carbon oxide that is utilized under Section 45Q(f)(5). Pass‑through elections are documented on Schedule E.
- You must attach the right certifications on time. For utilization, the IRS requires an approved lifecycle analysis, LCA, following Notice 2024‑60, before you can claim the credit. Late or incomplete documentation means no credit for that year.
- Binding written contracts must be enforceable and cannot cap damages below 5 percent of the contract price. Multiple contracts are allowed.
- Recapture uses a five‑year lookback with a last‑in, first‑out approach. Track leaked tons, document events, and report recapture in the year identified.
- Elective pay under 6417 and transferability under 6418 apply to many 45Q projects placed in service after 2022 and require pre‑filing registration if you use those options.
What Schedule F Covers Now
Schedule F is the Utilization Certification that supports credits claimed for qualified carbon oxide utilized as described in Section 45Q(f)(5). It is part of the IRS’s updated package of Form 8933 schedules. The December 2024 instructions introduced Schedules A through F, each tied to a specific role in the 45Q chain.
The Form 8933 Schedules, at a Glance
| Schedule | What it certifies | Who typically files it |
| Schedule A | Disposal or EOR owner certification | Owner of the geologic disposal site or EOR project |
| Schedule B | Disposal operator certification | Operator of the geologic disposal site |
| Schedule C | EOR operator certification | Operator of the EOR project |
| Schedule D | Recapture certification | Taxpayer reporting a recapture event |
| Schedule E | Election certification, pass‑through to another taxpayer | Electing taxpayer who allows another to claim the credit, and included by the claimant |
| Schedule F | Utilization certification | Taxpayer claiming utilization credits under 45Q(f)(5) |
Source for schedule definitions, roles, and filing mechanics.
Why the Change Matters
If your team previously treated “Schedule F” as a pass‑through schedule, update your workflows now. The 2024 instructions formalized each schedule’s purpose. In practice, that means:
- Use Schedule F when you claim utilization credits and have an approved LCA.
- Use Schedule E when you allow a disposer, injector, or user to claim your credit, or when you are the claimant receiving that pass‑through.
- Attach the right operator and owner certifications, Schedules A to C, based on your project setup.
- Use Schedule D if you have recapture in the current year.
No credit is allowed for a tax year if any required documentation or certification is missing or late. File a complete package with your timely return, including extensions.
Where Schedule F Fits In Your Filing Timeline
Here is the practical flow many teams follow during a utilization year:
- Confirm placed‑in‑service and the 12‑year credit window for the equipment tied to the utilized CO₂.
- Complete and submit your LCA package under Notice 2024‑60, coordinate with DOE, and wait for IRS approval. You must have approval before claiming utilization credits.
- Assemble your Form 8933 package. Include Schedule F for utilization, and include any related schedules for disposal or EOR if part of your project scope.
- If you are passing credits to another taxpayer, or receiving them, prepare Schedule E and exchange the required statements.
- Validate EPA Subpart RR or ISO 27916 evidence in your workpapers. Choose the correct verification path and keep the independent certification if you use ISO.
You will notice the IRS also highlights elective pay and transferability for certain taxpayers starting with facilities or equipment placed in service after 2022. If you use 6417 or 6418, complete pre‑filing registration before the return, then include the registration number on your forms.
Who Must Complete Schedule F
You file Schedule F when you claim credits for qualified carbon oxide that is utilized, not disposed in secure geologic storage or injected for EOR. Utilization means the CO₂ is used in a way that results in a net reduction of lifecycle greenhouse gas emissions, for example certain chemical processes documented by an approved lifecycle analysis. The IRS requires approval of your LCA under Notice 2024‑60 before any utilization credit is determined for the year.
- If you capture and utilize CO₂ at your facility, attach Schedule F to Form 8933 with your timely return.
- If you capture CO₂ and allow another party to claim the credit because they dispose of, inject, or utilize it, document that election on Schedule E, and the claimant includes a copy of your Schedule E with their Form 8933. You do not use Schedule F unless you yourself are the utilization claimant.
If You Are The 45Q Utilization Claimant
When you claim utilization credits, your steps include:
- Complete LCA procedures and obtain IRS approval as required by Notice 2024‑60. The DOE coordinates intake for the LCA submission email process, then the IRS issues its approval decision.
- Maintain monitoring and measurement records consistent with your LCA scope and internal controls.
- Prepare Form 8933 and Schedule F that match the approved LCA boundaries, tons, and time period.
- If your utilization is part of a larger chain that includes disposal or EOR, attach the proper owner and operator certifications where required, Schedules A to C, so your packet is complete.
Deadlines, Attachments, and “No Documentation, No Credit”
The IRS is unambiguous. You must submit complete documentation and certifications by the due date of the return, including extensions, for the year you claim the credit. If any required certification is late, the credit is not allowed for that year. This rule applies to both electing taxpayers and credit claimants.
File a complete, timely Form 8933 package. Include Schedule F for utilization, Schedule E for pass‑throughs, the right owner and operator certifications, and your LCA approval letter. No complete packet, no credit.
Subpart RR, ISO 27916, and What You Attach
- Subpart RR path. If your CO₂ is tied to Class VI wells with an EPA‑approved MRV plan, you generally use the mass‑balance approach and supporting GHGRP records. Keep e‑GGRT IDs and MRV approvals handy for your files.
- ISO 27916 path. For EOR and certain utilization, you can rely on ISO 27916 documentation, but a qualified independent engineer or geologist must certify your internal calculations and monitoring evidence. Include that certification with your return.
The Pass‑Through Piece Lives On Schedule E
Many firms still think Schedule F is where you show pass‑through allocations. Today, pass‑through elections that allow another taxpayer to claim your credit are documented on Schedule E. Both the electing taxpayer and the claimant have reporting duties, including listing the full dollar amount of the credit attributable to the electing taxpayer and the portion allowed to the claimant, along with corresponding metric tons.
Here is the mechanical reality for a pass‑through year:
- Electing taxpayer completes Schedule E for each site or contract where credits are allowed to a claimant.
- The claimant includes a copy of the electing taxpayer’s Schedule E with its Form 8933 and fills in claimant details that tie back to Schedule E.
- Everyone files on time. Late documentation equals no credit for the year.
Practical Example, Utilization Claim
Say you run a utilization process that mineralizes captured CO₂ into a product. You submitted your LCA in September 2025, received IRS approval in November 2025, and your tax year ends December 31, 2025. Your filing stack for 2025 includes:
- Form 8933, with Schedule F for utilization.
- The IRS LCA approval letter and supporting documentation described in Notice 2024‑60.
- Any applicable Schedule A, B, or C if the chain also involved disposal or EOR components linked to your claim.
Contracts, Elections, and Allocations Without Chaos
If you rely on contracts rather than doing everything yourself, the IRS expects enforceable, binding written contracts. The binding contract must be enforceable under state law against both parties and cannot limit damages to a specified amount. A damages cap at or above 5 percent of the total contract price is acceptable and will not be treated as limiting damages to a specified amount. You may use multiple contracts covering capture, disposal, injection, or utilization.
Binding Contract Checklist
- Enforceable under state or local law against both parties.
- No damages cap below 5 percent of the total contract price.
- Performance standards and data reporting cadence spelled out.
- Prompt leak notification and remediation triggers.
- Clear allocation of roles for Form 8933 schedules and annual certifications.
Pass‑Through Election, Now on Schedule E
When you allow another taxpayer to claim the credit, you make a Section 45Q(f)(3)(B) election and document it on Schedule E. The claimant includes your Schedule E with its Form 8933. The instructions list the information each party must provide, including names, TINs, facility locations, e‑GGRT IDs, total credits attributable before the election, and the portion allowed to each claimant with corresponding metric tons.
Multiple contracts are normal. Report the existence of each contract and the parties on Form 8933 annually, and exchange signed schedules so both returns match.
Elective Pay and Transferability
For tax years beginning after 2022, many 45Q projects can use elective pay under Section 6417 or transfer credits for cash under Section 6418, subject to eligibility rules and pre‑filing registration. If you use either path, register before you file and include the registration number on your return. This can change who appears as the credit claimant on Form 8933 and Form 3800. Check the current IRS instructions each year.
Who Files What, In One Table
| Role | Schedules you attach | Notes |
| Capture owner claiming utilization | Schedule F, plus A to C if applicable | Must have LCA approval under Notice 2024‑60 |
| Disposer or EOR operator claiming credit | Schedule B or C, plus A if owner, and Form 8933 | Follow RR or ISO path as applicable |
| Electing taxpayer allowing another to claim | Schedule E | Provide required data to claimant annually |
| Claimant receiving pass‑through | Copy of electing taxpayer’s Schedule E with your Form 8933 | Your return must mirror the electing taxpayer’s Schedule E |
| Taxpayer with recapture | Schedule D and Form 4255 reporting | Report in the year identified, apply LIFO lookback |
Citations for filing mechanics and schedules.
Recapture Rules You Must Actually Use
Recapture is not theoretical. If CO₂ that supported prior credits leaks, you determine a recapture amount in the year you identify the leak. First compare leaked tons to tons securely stored or used in the same year. If leaked tons exceed securely stored or used tons, apply the last‑in, first‑out method across prior credit years, generally up to five years back, or until monitoring ends, and compute the recapture using the appropriate statutory rate for those layers.
What Triggers Recapture
- A verified leak or event that shows CO₂ was not securely stored or used during the recapture period.
- Multi‑party sites require pro rata allocation based on delivered CO₂ in affected years.
- Qualifying force majeure can be excluded if it meets regulatory definitions and is documented. Report the recapture on Form 8933 with Schedule D and include Form 4255.
A Quick Recapture Walkthrough
- You identify a leak in 2025. Your site securely stored 10,000 tons in 2025, but monitoring shows 14,000 tons leaked that are attributable to prior claims.
- Net leaked tons for recapture are 4,000. You apply LIFO, start with 2024 credits, then 2023, and so on, up to five years back, using each year’s rate.
- You report the recapture in your 2025 return, attach Schedule D, and reflect the amount on Form 4255.
Placed‑in‑Service, 12‑Year Window, and Proration
Your placed‑in‑service date starts the 12‑year period for Section 45Q credits for post‑February 9, 2018 equipment. If you placed equipment in service midyear, your first‑year capture may be prorated by days for minimum thresholds and reporting consistency. Refurbishments and expansions can create new placed‑in‑service dates for incremental capacity and must be tracked separately. Always align the equipment timeline with the facility and process train rules in the current instructions.
Verification Framework Interplay
- Subpart RR path, you submit and follow an EPA‑approved MRV plan and mass‑balance calculations.
- ISO 27916 path, you keep internal documentation and obtain an independent engineer or geologist certification.
- For utilization credits, you also need an IRS‑approved LCA under Notice 2024‑60 before claiming.
Common Filing Pitfalls
- Treating Schedule F as the pass‑through schedule. It is not. Use Schedule E for elections that allow another taxpayer to claim your credit.
- Missing the LCA approval when claiming utilization credits. Without approval, the credit is not allowed for that year.
- Late or incomplete certifications. The IRS explicitly denies credits for any year with missing or late required certifications.
- Contract gaps. Binding contracts that cap damages below 5 percent fail the standard. Fix them and keep a clean version on file.
- Weak recapture workpapers. You need the dates, tons, event narratives, and LIFO mapping to prior years.
A Practical, Repeatable Checklist
Use this quick checklist during close and return prep:
- Confirm placed‑in‑service and credit year for each process train.
- Pick your verification path, RR or ISO, and ensure evidence is complete.
- For utilization, submit the LCA package early, follow DOE intake instructions, then attach the IRS approval when received.
- Map contracts to schedules. Schedule E for elections, Schedule F for utilization, Schedules A to C for owners and operators, Schedule D for recapture.
- Tie out metric tons, dollar amounts, and counterparties across all returns.
- If using 6417 or 6418, complete pre‑filing registration and include the registration number on the return.
Where Teams Usually Stumble
Most teams do not lack expertise. They lack a controlled delivery system. Schedule F packages fall apart when workpapers are inconsistent, LCA timing is unclear, or pass‑through schedules do not match claimant returns. If you need help standardizing workpapers, naming conventions, review checklists, and turnaround SLAs, a disciplined partner can help you build reliable capacity without losing control. That is how firms avoid March panic and pass audits with confidence.
Note on fit: Accountably integrates trained offshore teams into firm workflows, including tax software and client portals you already use, to help you maintain documentation discipline, file on time, and keep review notes tight. Use this only if you want capacity with structure, not just more resumes.
Frequently Asked Questions
Is this the same “Schedule F” as the farm schedule?
No. On Form 8933, Schedule F is the Utilization Certification for Section 45Q. The farm Schedule F for reporting farm income is part of Form 1040, not Form 8933. Different forms, different purposes.
Do I need both Schedule E and Schedule F?
Use Schedule F if you claim utilization credits yourself. Use Schedule E if you allow another taxpayer to claim your credit or if you are the claimant receiving a pass‑through. Many projects will use one or the other in a given year, not both, unless you both utilize and also allow a separate pass‑through for another portion. Check the instructions and mirror data across parties.
What documents prove my utilization tons?
For EOR or other utilization, you either rely on Subpart RR evidence with an MRV plan or use ISO 27916 supported by an independent engineer or geologist certification. For utilization credits specifically, the IRS also requires an approved LCA under Notice 2024‑60 before any credit is determined.
How do elective pay and transferability affect Form 8933?
If you elect direct pay under 6417 or transfer credits under 6418 for eligible projects placed in service after 2022, complete pre‑filing registration and include the registration number. The claimant that actually claims the credit must complete Form 8933 and any applicable schedules. Review the instructions each year for updates.
Conclusion
You are now clear on what Form 8933 Schedule F does today. It certifies utilization. Pass‑through elections moved to Schedule E. The strongest filings read like a finished story, not a stack of PDFs. They have an approved LCA where required, clean contracts that meet the 5 percent rule, synchronized schedules across parties, and recapture logic you can defend. Build your process once, then run it every year. If you want a second set of eyes on your Schedule F workpapers and LCA timing, bring in support early, long before busy season.
Compliance note, current as of the IRS pages reviewed in October and December 2024 and updated through October 2025. Always check the latest IRS instructions and notices before filing.