SMART is the production-based tariff that makes commercial solar work in Massachusetts, and for most projects it is the largest revenue line in the model. The current version is SMART 3.0, which replaced the declining-block structure people still describe in older proposals. Here is how Program Year 2026 actually works.
SMART 3.0 is open and Program Year 2026 runs through December 31, 2026 with 600 MW AC of capped capacity. Base rates are $0.2807 per kWh for systems above 25 to 250 kW AC, $0.2430 for 250 to 500 kW, $0.2317 for 500 kW to 1 MW, and $0.1790 above 1 MW, all for a 20-year term. A project may claim one location-based adder and one off-taker-based adder, with a narrow brownfield exception. DOER set PY2026 rates roughly 20 percent above its own cost model to offset federal tax credit risk, and the DPU approved company-specific tariffs on July 8, 2026. The 20-year term begins when the Final Statement of Qualification is issued and is not backdated to commercial operation, and behind-the-meter compensation nets out the Value of Energy rather than paying gross.
Program status as of August 2026
SMART 3.0 is the active program, and Program Year 2026 is open. The sequence below matters, because a great deal of published material about SMART still describes the 2.0 program that 3.0 replaced.
| Date | Event |
|---|---|
| June 20, 2025 | DOER files emergency regulations creating SMART 3.0 under 225 CMR 28.00 |
| September 12, 2025 | Final regulations take effect |
| December 1, 2025 | Final Program Year 2026 Annual Report published, setting rates and capacity |
| January 1, 2026 | PY2026 application window opens, running through December 31, 2026 |
| May 19, 2026 | Department of Public Utilities approves the revised SMART 3.0 tariff |
| June 26, 2026 | DOER files new emergency regulations with administrative corrections and a narrow eligibility carve-out for advanced-stage projects likely to qualify for the federal credit |
| July 8, 2026 | DPU approves company-specific tariffs for Eversource, National Grid, and Unitil. DOER begins issuing Final Statements of Qualification |
| August 7, 2026 | DOER holds a virtual public hearing on the June emergency regulations |
| September 11, 2026 | DOER files final revised 225 CMR 28.00 regulations with the Secretary of the Commonwealth |
| September 25, 2026 (expected) | Final regulations expected to publish in the Massachusetts Register |
The July 8, 2026 tariff approval is the practically important one. Until it happened, DOER was not issuing Final Statements of Qualification, which is the document that starts your 20-year compensation clock.
What SMART 3.0 changed from SMART 2.0
If your understanding of SMART comes from a proposal written before mid-2025, several of its core assumptions are now wrong.
| Element | SMART 2.0 (225 CMR 20.00) | SMART 3.0 (225 CMR 28.00) |
|---|---|---|
| Base rates | Fixed per capacity block, declining 4 percent per block | Set annually through the Annual SMART Program Assessment |
| Total capacity | 3,200 MW across declining blocks | Set annually. PY2026 has 600 MW AC subject to the cap |
| Tariff term | 10 years for systems of 25 kW AC or less, 20 years above | 20 years for all project sizes |
| Land use treatment | Greenfield subtractor | Weighted Mitigation Fee |
| Rate volatility limit | Not applicable | Annual change capped at 20 percent or 1 cent per kWh, whichever is greater |
The move from fixed declining blocks to annually set rates is the structural change with the most consequence. Under 2.0, you could read the block schedule and know roughly what a future project would earn. Under 3.0, the rate for next year is a policy decision made each December, bounded by the 20 percent or 1 cent annual change limit.
Program Year 2026 rates
| Capacity (kW AC) | PY2025 | PY2026 final | PY2026 as modeled |
|---|---|---|---|
| Above 25 to 250 | $0.2821 | $0.2807 | $0.2339 |
| Above 250 to 500 | $0.2482 | $0.2430 | $0.2025 |
| Above 500 to 1,000 | $0.2113 | $0.2317 | $0.1931 |
| Above 1,000 to 5,000 | $0.1729 | $0.1790 | $0.1492 |
The third column is the part worth understanding. DOER's cost model, built by BW Research using NREL's System Advisor Model with Massachusetts cost inputs, indicated that rates should come down significantly. DOER instead set final rates approximately 20 percent above the modeled values, explicitly citing the revocation of the federal tax credit and elevated post-OBBBA risk.
In plain terms: Massachusetts raised its own incentive to compensate for federal uncertainty. The only band that increased materially year over year was 500 kW to 1 MW, up about 9.7 percent. The bands at 500 kW and below came down slightly.
Two further rates: systems of 25 kW AC or less receive a Flat Incentive Rate of $0.03 per kWh, and Low Income generation units receive $0.06 per kWh.
Adders, and the stacking rules people get wrong
Adders are added to the base rate and paid on every kilowatt-hour for the full term. They are frequently the difference between a marginal project and a good one.
| Category | Adder | Value |
|---|---|---|
| Location | Dual-use agricultural | $0.09 |
| Location | Solar canopy | $0.08 |
| Location | Landfill | $0.06 |
| Location | Brownfield | $0.04 |
| Location | Floating | $0.04 |
| Location | Large building mounted, 900 kW AC and above | $0.04 |
| Location | Raised racking | $0.04 |
| Location | Building mounted | $0.03 |
| Off-taker | Community shared | $0.07 |
| Off-taker | Low income property | $0.05 |
| Off-taker | Public entity | $0.04 |
| Other | Energy storage multiplier | $0.04 |
| Other | Pollinator | $0.01 |
| Other | Solar tracking | $0.01 |
The stacking rule. A project qualifies for one location-based adder and one off-taker-based adder. They do not accumulate. The single exception is brownfield, where a project may add one additional location-based adder. Proposals that sum three or four location adders into a headline rate are wrong, and the error is usually large.
Two of the newer adders deserve specific mention. Large building mounted, at $0.04, is new in 3.0 and rewards the largest rooftop projects. Raised racking, also $0.04 and also new, is aimed at systems elevated above the surface they sit on. The canopy definition was broadened in 3.0 to cover any qualifying secondary function including parking, walkways, transportation infrastructure, storage, and canals, provided at least 75 percent of the panels overlap that secondary function.
Storage changes in 3.0
- Systems of 25 kW AC or less are no longer eligible for the storage adder.
- The project size that triggers a mandatory storage requirement rose from 500 kW to 1 MW.
- The energy storage requirement does not apply to generation units receiving a location-based adder.
- The multiplier was raised from $0.0265 to $0.045 during PY2025 and set at $0.04 for PY2026.
For commercial hosts with demand charge exposure, the storage adder is only part of the case. Utility demand response revenue and peak shaving usually matter more. See battery revenue from demand response and reducing peak demand charges.
Capacity, allocation, and set-asides for PY2026
PY2026 has 600 MW AC subject to the capacity cap, raised from the 450 MW proposed in the draft report. Two categories are exempt from the cap in PY2026 and therefore do not consume it: systems of 25 kW AC or less, and behind-the-meter systems above 25 up to 250 kW AC.
| Utility | Share of block | Capacity |
|---|---|---|
| Eversource | 49.01 percent | 294.06 MW |
| National Grid | 45.15 percent | 270.9 MW |
| Unitil | 5.84 percent | 35.04 MW |
Minimum set-asides: 10 percent, or 60 MW, for standalone systems above 25 to 500 kW AC; 10 percent, or 60 MW, for Low Income Property; and 15 percent, or 90 MW, for Community Shared Solar. Unused capacity is not reallocated between categories during the year.
A useful reality check on scarcity. In PY2025, DOER received 387 applications totaling 191.9 MW, which is only 21.3 percent of available capacity, well below the roughly 750 MW pipeline stakeholders had projected. Whatever else is constraining Massachusetts commercial solar right now, SMART capacity is not the binding constraint. Interconnection and federal tax uncertainty are the more likely culprits.
Program size limits: 5 MW AC generally, with brownfield and landfill projects permitted up to 10 MW AC.
How you actually get paid
SMART compensation depends on whether the system is behind the meter or standalone.
| Configuration | Compensation formula |
|---|---|
| Above 25 kW AC, behind the meter | (Base rate plus adders minus Value of Energy) multiplied by kWh generated |
| Above 25 kW AC, standalone | (Base rate plus adders) multiplied by kWh generated, minus Value of Energy generated |
| 25 kW AC or less | Levelized Revenue Requirement minus the prior year average residential net metering credit value |
The Value of Energy term is the point people miss. SMART is not a gross payment on top of your bill savings; the tariff nets out the value of the energy you are already capturing. DOER publishes a Behind-the-Meter Value of Energy workbook, effective through December 31, 2026, and that workbook is what a credible pro forma should be using.
The 20-year term starts later than you think
Two mechanics with real financial consequences:
- The 20-year term begins when the Final Statement of Qualification is issued, not when the system starts producing.
- DOER states that SMART incentive payments are not backdated to a project's commercial operation date. Generation before qualification is not compensated under the tariff.
That makes application sequencing a financial decision rather than an administrative one, and it is a specific reason to be careful with contractors who treat the SMART filing as paperwork to handle after construction.
Reservation periods and the interconnection reality
Uncapped categories are processed on a rolling first-come basis. Capped projects go through an initial 10-day window sequenced by ISA application date, then first-come first-served, with a public waitlist.
| Situation | Reservation period |
|---|---|
| Standard | 24 months |
| Project within an approved Capital Investment Project | 48 months |
| Project in interconnection study or at mechanical completion | Extensions available |
The 48-month provision exists because of a real problem. Massachusetts created the Capital Investment Project framework precisely because distributed generation began triggering distribution upgrades far more expensive than historical interconnection costs. Under that framework, ratepayers fund qualifying upgrades and the generators that benefit repay through fees over time, which is a cost line that belongs in your model.
We will not publish typical interconnection durations, because no Massachusetts utility or state body publishes credible current figures for commercial group study timelines. What is documented is that group study timelines have been a recurring agenda item at the state's Interconnection Implementation Review Group since October 2025, and that in January 2026 the Healey-Driscoll administration announced a joint initiative with Eversource and National Grid to accelerate connections. Treat any contractor who quotes you a confident interconnection timeline without a circuit-specific basis with appropriate skepticism.
Land use: the Mitigation Fee and outright ineligibility
For ground-mounted systems above 250 kW AC that are not on previously developed land, SMART 3.0 replaced the old greenfield subtractor with a weighted Mitigation Fee, calculated as a maximum per-acre fee multiplied by a weighted score across carbon storage, ecological integrity, agricultural potential, critical landscape, and geographic distribution, multiplied by acres impacted. A down payment is due 30 days after the Statement of Qualification, and an external Environmental Monitor site visit is required at the project's expense.
More consequentially, a project of that description can be ineligible for SMART entirely if it overlaps BioMap Core Habitat, places more than 10 percent of its footprint in the top 20 percent of forest carbon, or overlaps protected open space, wetland resource areas, or the State Register. In PY2025, only 4.3 percent of applications were subject to the Mitigation Fee, but those represented 25.1 percent of capacity, which tells you it is concentrated in the largest ground mounts.
This screening belongs at the very start of a ground-mount project. See leasing land for a solar farm and our solar farm development service.
If your project started under SMART 2.0
- Eligible for 3.0 if on-site construction did not begin before June 20, 2025, or before July 1, 2024 for Low Income Property, and the project never received a SMART or RPS Class I incentive.
- SMART 2.0 accepted applications through December 31, 2026, requiring construction started before December 31, 2025 or a demonstration of significant investment before that date.
If you hold a 2.0 position, the comparison is worth running rather than assuming. The 2.0 rates for some bands were higher, but the 3.0 term is 20 years for all sizes where 2.0 gave only 10 years to the smallest systems.
How SMART interacts with net metering
SMART and net metering are separate mechanisms and both apply. Net metering governs what you are credited for exported energy; SMART pays a tariff on generation.
The net metering detail that most affects commercial sizing: under Massachusetts rules, new solar Class II and Class III facilities are generally credited on the basis of 60 percent of net excess generation, while facilities that are cap exempt because they serve on-site load receive 100 percent. That materially favors sizing a commercial array to the building's own consumption rather than to the maximum the roof will hold. Note also that a proceeding on net crediting, D.P.U. 25-117, has been active during 2026 with a technical conference held in February, so this is an area to confirm rather than assume.
Key takeaway. SMART 3.0 is open, PY2026 rates are set, and the DPU approved company-specific tariffs on July 8, 2026, so Final Statements of Qualification are being issued. Base rates run from $0.2807 per kWh at 25 to 250 kW AC down to $0.1790 above 1 MW AC, all for a 20-year term, with one location adder and one off-taker adder permitted. DOER set those rates roughly 20 percent above its own model to offset federal tax risk. The three things that most often surprise commercial hosts are that the 20-year clock starts at qualification and is not backdated, that the tariff nets out the Value of Energy rather than paying gross, and that interconnection rather than SMART capacity is the real constraint on schedule.
Sources
- Massachusetts DOER, SMART 3.0 Program Details. mass.gov
- Massachusetts DOER, Program Year 2026 Annual Report. mass.gov
- Massachusetts DOER, SMART 3.0 Overview. mass.gov
- Massachusetts DOER, SMART 3.0 FAQ. mass.gov
- Massachusetts DOER, PY2026 Behind-the-Meter Value of Energy Workbook. mass.gov
- Massachusetts DOER, Mitigation Fee Instructions. mass.gov
- Massachusetts DPU, Net Metering Guide. mass.gov
- Massachusetts DOER, Interconnection Implementation Review Group notes. mass.gov
Program rules, rates, and capacity are set annually and were amended by emergency regulation in June 2026, and DOER filed final revised regulations on September 11, 2026, with Massachusetts Register publication expected September 25, 2026. Confirm current figures with DOER or with us before relying on them in a financial model.