Vistra Corp.

5. GOVERNMENT GRANTS

Inflation Reduction Act of 2022 (IRA)

In August 2022, the U.S. enacted the IRA, which introduced various energy tax credits. Among these, it acknowledged the importance of existing carbon-free nuclear power by establishing a nuclear Production Tax Credit under section 45U (nuclear PTC), a solar PTC, new technology-neutral ITCs and PTCs that apply to various different clean energy technologies, and a new stand-alone battery storage investment tax credit. The nuclear PTC provides a federal tax credit of up to $15 per MWh, subject to phase out when annual gross receipts are between $25.00 per MWh and $43.75 per MWh and $26.00 per MWh and $44.75 per MWh for 2024 and 2025, respectively. The nuclear PTC applies to existing nuclear facilities from 2024 through 2032 subject to an annual inflation adjustment. The Company accounts for transferable ITCs and PTCs we expect to receive by analogy to ASC 832.

Transferable PTCs

In the years ended December 31, 2025 and 2024, we recognized transferable nuclear PTC revenues of $220 million and $545 million, respectively. Nuclear PTC revenues are an estimate based on annual gross receipts generated from qualifying nuclear production in 2025 and 2024 and reflect our determination that we will meet the prevailing wage requirements necessary to earn the five times multiplier. Our computation of gross receipts includes settled spot energy revenues and capacity revenues (applicable to our PJM nuclear units only) at each nuclear unit and excludes any hedges and ancillary service revenue. Treasury regulations may further define the scope of the legislation in many important respects, including interpretive guidance on the definition of gross receipts for the nuclear PTC. Any interpretive guidance on the definition of gross receipts that differs from the interpretation used in our estimate could result in a material change to PTC revenues recorded in 2025 and 2024 and would be reflected as a change in estimate in the period in which the guidance is received.

Transferable ITCs

In October 2025, our Oak Hill 200 MW solar facility in Texas met the requirements to be placed in service. As a result, in the year ended December 31, 2025, we recognized $98 million of transferable ITCs associated with the project in other noncurrent assets in the consolidated balance sheet.

In December 2024, our Baldwin 68 MW solar /2 MW battery ESS and Coffeen 44 MW solar /2 MW battery ESS facilities in Illinois met requirements to be placed in service. As a result, in the years ended December 31, 2025 and 2024, we recognized transferable ITCs of $(2) million and $57 million, respectively, associated with Baldwin, and $(1) million and $45 million, respectively, associated with Coffeen, in other noncurrent assets in the consolidated balance sheet.

In June 2023, our 350 MW battery ESS at our Moss Landing Power Plant site (Moss Landing Phase III) in California commenced commercial operations. As a result of Moss Landing Phase III meeting requirements to be placed in service in June 2023, we recognized $154 million of transferable ITCs associated with the project in other noncurrent assets in the consolidated balance sheet. In September 2024, we recognized an additional $2 million of transferable ITCs associated with the project and reclassified the $156 million of credits to other current assets.

Sales of Transferable PTCs and ITCs

During 2025, we sold $490 million of transferable nuclear PTCs recognized from qualifying 2024 nuclear generation, of which $200 million was sold in January 2025, $90 million was sold in May and June 2025, and $200 million was sold in September 2025. Cash proceeds of $469 million were received during the year ended December 31, 2025.

In October 2024, we sold $156 million of transferable ITCs and $10 million of transferable solar PTCs generated in 2023. Vistra received cash consideration from the sale in October 2024.