Who Owns a Solar Farm, and Can It Be Tokenized?

A solar owner asking whether a project can be tokenized is really asking three separate questions: who does the paperwork say owns this, what proves it produces, and what would an investor actually hold. Most tokenization content skips straight past all three and into a market-size number. This piece answers the first two from the primary federal source, because the answers are more specific, and more useful, than the framing usually allows.

Who does the paperwork say owns it?

The dataset everyone cites for US solar is the Energy Information Administration's Form EIA-860, the Annual Electric Generator Report. Filing is mandatory for every grid-connected generator of 1 megawatt or more, under Section 13(b) of the Federal Energy Administration Act of 1974, with a civil penalty of up to $13,273 per day per violation. As of the 2025 final release it covers 7,999 operable solar photovoltaic generators totaling 152,895 megawatts of nameplate capacity.

Here is the counterintuitive part. EIA-860's ownership schedule — the table that names each owner, by name and mailing address, with a percentage interest to two decimal places, totaling 100 — is completed only when a generator is jointly owned, or wholly owned by someone other than the entity that files the form. That schedule names an owner for 23,627 of 152,895 megawatts: roughly one sixth of US solar capacity. The other 129,238 megawatts, across 6,470 generators, are coded "single ownership by respondent" — the filer is the owner, and that name sits in a different schedule entirely, not the one built to look like a cap table.

Where the ownership schedule does apply, it is genuinely cap-table-shaped: named owners, exact percentages, a total that reconciles to 100. That structure is not an accident. It is the federal government already keeping the record a tokenized ownership interest needs — for the fraction of the fleet where more than one party holds a stake.

What actually proves it produces power?

Ownership on paper is one question. Production is another, and this is where the public record has a hard edge.

Form EIA-923, the companion generation and fuel report, is filed at different frequencies depending on plant size — and the frequency gap is large. Share of US solar plants filing generation data monthly during the year, by size:

| Plant size | Reports monthly |
|---|---|
| 1–5 MW | 2.0% |
| 5–20 MW | 4.1% |
| 20–75 MW | 62.8% |
| 75–200 MW | 93.5% |
| 200 MW and up | 96.8% |

Below 20 megawatts, monthly reporting is close to nonexistent. Above 20 megawatts, it is close to universal. And even the annual file, which every plant eventually files, arrives late: the 2025 data was published on 2026-09-11, roughly nine months after the year it describes.

The size of that gap is worth stating plainly, because it was not obvious from the published documentation alone. The release's own layout sheet defines frequency codes `M` (monthly) and `A` (annual), but a third code, `AM`, appears on the majority of solar rows and is undefined by the publisher. Resolving it took a population comparison: the in-year monthly release carries 1,271 solar plants; the final annual release carries 7,198. The smaller plants simply do not file during the year — `AM` behaves like an annual-only code in practice, whatever it is meant to mean on paper.

So for a plant under 20 megawatts, there is no public, timely record of what it actually generated or what that generation was paid. That has to come from the owner's own revenue-grade metering and settlement statements — the utility or offtaker's paid invoices, not a public database.

What would an investor actually hold?

Operating solar with a contracted offtake is tokenizable, with a specific and ordinary piece of work in front of it, not a vague one. The ownership side is unusually clean for a real-world asset: a federal filing, made under penalty, that states who owns the generator and in what share, at least for jointly held projects. The production side is the actual gap, and it is a data-plumbing problem, not a legal or structural one. An investor in a tokenized solar interest needs to see what the asset generated and what that generation was paid, and for smaller plants that record exists only on the owner's own systems, in whatever format the owner happens to keep it.

Put plainly: the paperwork that proves you own a solar farm is public and free. The paperwork that proves it earns money is yours alone, and turning it into something a holder can check is the real work of structuring the deal — not a regulatory hurdle, an operational one.

This is not a solar-only problem, and it is worth saying once directly: whatever the asset class, tokenizing it starts with the same three questions — who does the record say owns it, what proves it performs, and what would the resulting interest actually represent. Solar simply has an unusually well-documented version of question one and an unusually well-documented gap in question two, because the federal government happens to publish both.

What we're not saying

This piece draws no conclusion about what a tokenized interest in a solar project is under securities law — that determination belongs to counsel, made deal by deal, under whatever exemption applies. And it does not claim Commertize can supply a missing production record for any given plant today; where the public data ends, that record still has to come from the owner, in a form a verification process can check.

Sources: US Energy Information Administration, Form EIA-860 (Annual Electric Generator Report) and Form EIA-923 (Power Plant Operations Report), 2025 final release plus the 2026 in-year release, downloaded from eia.gov.

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