The U.S. Department of Energy (DOE) has implemented the Energy Dominance Financing (EDF) program, a federal credit-support framework that recalibrates how DOE provides loan guarantees for energy infrastructure. The program is administered through DOE’s Office of Energy Dominance Financing, the restructured successor to the former Loan Programs Office, as described in DOE’s official overview of the Energy Dominance Financing Program.
According to DOE, the Energy Dominance Financing Program operates under its Title XVII loan guarantee authority and is intended to support projects that add energy to the grid, enhance reliability, or retool, repower, repurpose, or replace existing infrastructure, consistent with the program description published by the Department. The statutory basis for this authority is Section 1706 of Title XVII of the Energy Policy Act, which authorizes DOE to provide loan guarantees for qualifying energy infrastructure projects.
DOE formally operationalized the EDF framework through an interim final rule published in the Federal Register on October 28, 2025, which revised DOE’s loan guarantee regulations to broaden the definition of eligible energy infrastructure and expand project eligibility. The interim final rule took effect upon publication and governs how DOE evaluates new and pending applications under the EDF framework.
As part of this implementation, DOE reorganized its internal structure, renaming the former Loan Programs Office as the Office of Energy Dominance Financing, as reflected in DOE’s updated organizational and programmatic materials. Under the current structure, this office oversees EDF alongside other Title XVII financing authorities and related federal credit programs.
Importantly, DOE has not announced any policy to rescind, reopen, or re-adjudicate loan guarantees approved and executed prior to the implementation of EDF. Consistent with long-standing federal credit practice, previously executed guarantees remain in effect unless affirmatively modified or terminated by the Department. Those financings are now administered within DOE’s current organizational framework, even as the policy lens governing future approvals has evolved toward reliability, capacity, and energy security.
For additional analysis on federal energy financing programs and their interaction with energy regulation and infrastructure development, see Maceira Zayas Law & Strategy’s Energy & Infrastructure Insights, which provides ongoing coverage of these developments.
