What's New in California's LCFS: Electricity & Equipment Edition

California’s latest LCFS rulemaking adds several quiet but consequential changes for anyone who earns, or plans to earn, credits from electricity. Four themes stand out:

• Fast-Charging Infrastructure (FCI) crediting
• Mandatory direct-metering reporting for electric forklifts
• Multi-family residential charging
• Full third-party verification for every electricity transaction report

Fast-Charging Infrastructure (FCI) crediting

California has updated the “capacity-based” credit pathway that rewards DC fast-charging sites even when utilization is low. The key takeaways:

• Four distinct pathways. Light/medium-duty (LMD-FCI) and heavy-duty (HD-FCI) for electricity, plus two mirrored pathways for hydrogen.
• 10-year credit life, first-come first-served. Apply before 31 Dec 2030 (LMD) or 31 Dec 2035 (HD), or until statewide infrastructure credits hit 2.5% of prior-quarter deficits.
• Capacity vs. consumption. Each quarter you receive a combination of the normal energy-based credit and a capacity credit that uses a 20% (public/shared) or 10% (private) utilization factor.
• Guardrails. Once you recover 150% of net capital cost, or use the full ten-year allotment, a site may only generate consumption-based credits.
• Design implications. Higher uptime, as reported by the network, and public accessibility both boost the capacity factor and therefore credit revenue.

Forklift charging: no more estimation

Since 2017, facility owners and operators have been allowed to estimate forklift electricity based on a variety of forklift and charger operational variables. That option is now sunset:

• Cut-off date. Beginning with the 2026 compliance year, only directly metered electricity can earn LCFS credits.
• Meter specs. ±5% accuracy on a six-year calibration cycle, per §95491.2(a).

Action checklist:

1. Inventory chargers and decide whether retrofitting revenue-grade meters is cost-effective.
2. Update standard operating procedures — operators must keep 24 months of raw interval data on file for verifiers.

Multi-family residential charging

CARB has added an opportunity for owners and operators of EV chargers at multi-family dwellings to receive credits, by redirecting LCFS credits from the utility to the charger owner.

• Eligibility. A charger at a multi-family residence consisting of at least 4 condominium dwelling units, or at least 3 apartment dwelling units.
• The charger cannot be limited to serving dedicated or reserved parking spaces.

Why it matters: allowing multi-family residential charging to receive credits starts to address a lot of the equity issues within the program around residential charging outside the context of home ownership. It encourages new and existing developments to think about EV charging as part of the service package they offer residents.

Verification requirement for electricity as a fuel

Beginning with the 2026 data year, every LCFS electricity transaction report — whether for EVs, forklifts, yard hostlers, cranes, or eTRUs — must undergo third-party verification by an ARB-accredited verification body. The details:

• Tiered risk approach. Low-risk reporters, generating fewer than 10,000 credits per year, may use a limited-scope desk review. Everyone else faces a full data-sampling audit.
• Timeline. The verification statement is due August 1 following the reporting year, aligning electricity with liquid-fuel timeframes.

Closing thoughts

CARB’s 2024 overhaul, approved in 2025, shifts the electricity conversation from how much you dispense to how transparently you measure and verify it. Whether you run a public truck stop, a grocery distribution center, or a port terminal, the winning formula is now accurate meters and EVSE plus robust data systems, which together mean bigger and safer LCFS revenue.

Have questions about implementing these changes? Reach out to our team — we’ve helped countless fleets and site hosts navigate credit strategy from application through verification.

Disclaimer: This article is for informational purposes only and does not constitute legal advice.