Illinois Shines Escrow Process
Protecting consumers throughout their Illinois Shines experience is a priority of the Illinois Power Agency and its Program Administrator. The Illinois Shines Consumer Protection team receives and investigates complaints and takes disciplinary action against vendors who have violated program requirements. The team also hosts a regular consumer protection working group, develops educational resources and tools, and provides other support to inform and protect customers.
The 2024 Long-Term Renewable Resources Procurement Plan authorized the development of new consumer protection initiatives, including the Escrow Process.
About the Escrow Process
- Addresses an issue of AVs promising to pass through some of their Illinois Shines REC incentive payment to customers and then failing to do so
- Developed by IPA and the Program Administrator with stakeholder feedback, with a Rationale Document published June 13, 2025
- Launched in June 2025
- Activated when there is a high likelihood that the AV would not pass promised REC incentives on to customers
- Directs utilities to make REC incentive payments to a third-party escrow entity to distribute to customers, with remainder to AV
Escrow Process (.pdf)
The escrow process allows the Program Administrator to direct utilities to make REC payments to a third-party entity who can be directed to pay customers promised REC incentives. Download the informational flyer here.
Escrow Process Success
Prior to implementing the general Escrow Process, the Program implemented a voluntary escrow process with a specific Approved Vendor, which had been suspended for its failure to provide promised pass-through payments to its customers.
In the voluntary escrow process, the utility paid Illinois Shines incentives to a third-party escrow agent, and the escrow agent passed promised incentive payments to the AV’s customers. Rather than passing through the remaining incentive to the AV, the AV authorized the escrow agent to use those funds to repay other customers who did not receive their promised payments.
moved forward through this voluntary escrow process, and these customers received their promised pass-through payments from the escrow agent.
This process also allowed the escrow agent to provide full, promised pass-through payments to another 39 customers who previously had not received their promised pass-through payment.
was paid out to the 196 customers whose projects went through the escrow process.
was paid out to earlier customers who had not received their promised payments.
– Illinois Shines customer
I thought I was out of options when I heard about the closure of Revolution Solar. Thank you all so much for helping everyone affected by this. I'm sure everyone appreciates what you are doing. Your department has been very communicative and helpful throughout the entire process.
- Basil Shareef, Illinois Shines Customer
Escrow Process Steps
Once the Escrow Process is implemented for a specific Approved Vendor, the Program Administrator will take the following steps:
1.
Work with the Approved Vendor and relevant utility to update payment directions so future invoices will be paid to the third-party escrow agent retained by the Program Administrator.
2.
Generate invoices for the Approved Vendor to submit to the utility for newly verified applications, directing the utility to pay the third-party escrow agent.
3.
Communicate with all customers to ensure it has the correct name and address for the payment checks.
NOTE: It is imperative that customers promptly respond to the Program Administrator regarding their escrow payment. If the Program Administrator has not heard from the customer for 30 days and still requires confirmation of the escrow amount and/or where to send the payment, it may direct the escrow agent to pay the customer’s project’s full incentive amount to the Approved Vendor (who will still be required to pass through any promised incentive payment to the customer).
4.
Determine the customer payment amounts by reviewing the customer’s Disclosure Form, contract with the Approved Vendor, and any additional information provided by the customer and Approved Vendor.
5.
Let the customer and the Approved Vendor know its final determination of the amount of the customer’s promised pass-through incentive amount. At this point, the customer and the Approved Vendor will have two weeks to contest the Program Administrator’s determination by emailing the Illinois Power Agency at [email protected], with cc: to the Program Administrator at [email protected]. The Illinois Power Agency will review and make final incentive payment decisions for any filed appeals.
6.
Provide the third-party escrow agent with the list of customers and final incentive amounts for payment.
7.
After the escrow agent receives payment from the utility, the Program Administrator will notify customers that payments are on their way. The escrow agent will then pay customers their promised incentive amounts and will pay any remaining funds to the Approved Vendor.
Frequently Asked Questions
Why is the escrow process being implemented for my Approved Vendor?
When the Program Administrator is made aware that an Approved Vendor failed to pass promised incentive payments through to its customers, it reaches out to customers to investigate and allows the Approved Vendor the opportunity to respond to these allegations. Following this investigation, the escrow process may be activated when there is a high likelihood that the Approved Vendor will not pass through promised REC incentive payments to customers and the contracting utility does not object to the escrow process. If your Approved Vendor is subject to escrow, it is because the above requirements were met.
(Updated August 2026)
Why can’t the Program Administrator have the incentive paid out directly to me?
The Illinois Shines program is structured in a way where Approved Vendors enter into a REC Contract with a utility for the delivery of Renewable Energy Credits for solar projects. The utility pays the incentive amount to the Approved Vendor. The Program Administrator and Illinois Power Agency do not have the authority to direct the utility to send incentive payments directly to end-use customers.
(Updated August 2026)
What are the next steps for my Illinois Shines application?
Customers can utilize the Project Lookup Tool to view the status of their application. A summary of the steps in the application process is located below the Project Lookup Tool.
(Updated August 2026)
Why was my incentive payment allowed to be paid directly to my Approved Vendor rather than going through the escrow agent?
As explained above, the normal process is that the Approved Vendor submits an invoice, and the utility then sends payment to the Approved Vendor. Once the Program Administrator has reason to believe an Approved Vendor is not timely passing through promised incentive payments to its customers, it may, at its discretion, temporarily pause the generation of new invoices for the Approved Vendor and/or pause verifying applications submitted by the Approved Vendor. However, by the time a determination is made that the Approved Vendor is not passing through promised payments, some customers have already been harmed, because the Approved Vendor received the funds related to their solar projects and did not pass through promised payments. These customers may be eligible for the Solar Restitution Program.
(Updated August 2026)
What do I do if I think the amount I received through this process was less than what the Approved Vendor promised me?
If you believe you are still owed pass-through incentive money from your Approved Vendor after receiving your escrow payment, you may be eligible for the Solar Restitution Program. The Solar Restitution Program allows customers who did not receive their fully promised incentive payments to apply for restitution and potentially receive additional funds. More details on the Solar Restitution Program can be found here. Please note that one prerequisite for restitution eligibility is that you will first have to file a complaint with the Program Administrator about the underpaid incentive. If you do not already have a complaint opened for your incentive payment, you may open one by filling out this form.
(Updated August 2026)