Project 2025 Tracker / What’s done, what’s next

12. Department of Energy and Related Commissions · Minor

Strengthen due diligence and transparency in DOE loan programs

Not started

384 12. Department of Energy and Related Commissions

“Strengthen due diligence and increase transparency in DOE loan programs.”

What has happened

  1. Not started

    The guidance describes the diligence DOE already does; it strengthens nothing and discloses less. The Office of Energy Dominance Financing issued its Title 17 Energy Financing Program Guidance on 13 May 2026, and it is the only document in the window that could carry this ask. It states that EDF's process "includes rigorous due diligence that is comparable to what is considered best practice in the private sector", that EDF "conducts a comparable review and due diligence process as commercial lenders", and that transactions pass internal EDF validation, interagency review by OMB and Treasury, the DOE Credit Review Board and the Secretary's approval — a description of the standing five-step process, not a new requirement added to it. On transparency the guidance runs the other way: its only disclosure section restricts the use and disclosure of applicant information and states that DOE "will not enter into Non-Disclosure Agreements" while protecting marked confidential business information. The October 2025 interim final rule on Energy Dominance Financing, the only loan-program rule in the window, amends eligibility and definitions to implement P.L. 119-21 and adds no diligence or disclosure provision.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • Negative search: the operative text of the Energy Dominance Financing Amendments interim final rule (Federal Register 2025-19675) was read at govinfo and contains no due-diligence or transparency provision; the Federal Register records we keep and search hold no other DOE loan-program rule in the window.
  • Reviewed 2026-09-06. The guidance found on 2026-08-31 but not then opened was read in full. It is reached from energy.gov/edf → energy.gov/edf/edf-applicant-resources, where the button labeled “Title 17 Energy Financing Program Guidance (May 2026)” points at energy.gov/media/360527, which redirects to the document landing page cited above; 60 pages. Searched for “due diligence” (12 hits, all descriptive), “transparen” (0), “disclos” (only the restrictions-on-disclosure section).
  • The Status did not change, but the guidance is cited on the not started event: real, dated, Primary action on the ask’s own subject that satisfies neither limb is attached to the event itself. This is the “moved nearby” case — DOE published program guidance about its loan diligence, and the guidance does not strengthen it.
  • Read alongside, not covered by this negative: #975 (the eligible-project limit, partial) and #976 (Uyghur Forced Labor Prevention Act qualification, not started), both of which the same guidance was searched for.
Action
other
Object
DOE loan programs
ID
974