September 24, 2026
Illinois has taken a significant step toward expanding access to distributed energy resources (DERs) for households. Through a series of workshops facilitated by the Illinois Commerce Commission (ICC), the state’s Equitable Energy Upgrade Program (EEUP) now has established guidelines to proceed with implementation and a clear regulatory framework shaped by input from utilities, advocates, and other stakeholders.
For states exploring ways to expand distributed energy resources (DERs) such as solar, battery storage, efficient heating & cooling equipment, and EV chargers, Illinois offers a practical example of how regulatory design can support widespread investment in these resources while maintaining strong consumer protections.
What is the Equitable Energy Upgrade Program (EEUP)?
The Illinois Equitable Energy Upgrade Program (EEUP) was established in 2021 under Public Act 102-0662 as part of Governor J.B. Pritzker’s Climate and Equitable Jobs Act (CEJA), which supports the state’s commitment to achieving 100% clean energy by 2050. The law directs the state’s large investor-owned electric utilities, Ameren Illinois and ComEd, to establish an Equitable Energy Upgrade Program modeled after the Energy Efficiency Institute’s Pay As You Save® (PAYS®) program.
The EEUP aims to expand household access to DERs by removing or significantly reducing upfront cost barriers that have historically limited Illinoisans’ ability to access energy-efficient equipment. With EEUP, utilities invest directly in DERs at a customer’s home or business and recover their investment through a fixed monthly charge (called the Participant Service Charge) on the customer’s bill that is less than the estimated bill savings produced by the upgrades. It’s designed to help households lower energy bills, improve resilience, reduce pollution, and access modern energy technology—without large upfront costs, credit requirements, or homeownership.
The ICC confirmed: With EEUP, utilities make investments in upgrades at homes and businesses.
Consistent with the findings of thirteen utility commissions, the Illinois Commerce Commission determined that the EEUP model enables utilities to make investments. Specifically, consistent with PAYS, utility investments in energy upgrades are estimated through site-specific modeling to reduce energy use and produce net bill savings on an annual basis. Utilities recover their investment at that site, and once recovery is complete, the Participant Service Charge stops.
EEUP-based programs are prohibited from creating personal debt for participants, cannot subject participants to a credit check, and cannot require a lien on the property or in any way obligate customers to continue payment after they move—the charge remains with the site. This helps ensure the program remains accessible to renters, low-income households, and customers with limited or no credit history.
The ICC adopted several guidelines to ensure strong consumer protections.
Deferred payment options for Participant Service Charges: If a customer falls behind on Participant Service Charges, the utility must offer a deferred payment plan of at least one year and evaluate whether the installed energy upgrades are performing as expected before taking further action.
The 80/20 savings test is a consumer protection, not a minimum required charge: The EEUP is designed to produce net savings annually for participating customers with an assurance: the Participant Service Charge can be no greater than 80% of the estimated savings for 80% of the useful life of the equipment. If a project is estimated to generate even greater savings, the utility must reduce the PSC so that those savings are passed on to the customer. In other words, with greater savings, participants can expect to receive more than 20% annual estimated net savings within the useful life of the equipment.
Renters cannot be required to make upfront copayments: Projects that do not meet the 80/20 savings test may require an upfront copayment from the participant. If a project requires a copayment, the ICC determined that only the property owner may provide it.
“Safe harbors” balance implementation flexibility with expanded energy efficiency offerings.
The ICC established a pathway for utilities to develop “safe harbor” measures for energy efficiency upgrades. A safe harbor is a pre-approved combination of technologies and building characteristics that will meet the 80/20 savings requirement, allowing projects to move forward without a full individualized cost-effectiveness analysis for each customer.
While utilities may initially prioritize solar and battery storage offerings, the ICC requires each utility to implement at least one energy efficiency safe harbor within four years of launching the EEUP and to submit supporting analysis as part of the program’s three-year evaluation. This approach gives utilities flexibility during early implementation while ensuring additional energy efficiency upgrades—weatherization, heating and cooling, and water heating—become core offerings of the program over time.
The Next Phase: Utility Implementation Plans
Illinois will directly launch the EEUP statewide from its first year. With guidance now in place, utilities must file Implementation Plans within the next four months for programs that comply with the guidelines. They will define how each offering will operate in practice for each utility.
These plans will shape how effectively the EUUP reaches the households it was designed to serve, including how it integrates with existing initiatives such as the Illinois Home Weatherization Assistance Program (IHWAP), the Low Income Home Energy Assistance Program (LIHEAP), Illinois Solar for All (ILSFA), Illinois Shines, and virtual power plant opportunities under the Climate and Resilient Grid Act (CRGA).
“The Equitable Energy Upgrade Program has the potential to make clean energy upgrades—and the savings they can bring—more accessible for Illinois households. We’ve spent years working to bring this Pay-As-You-Save type model to Illinois, starting with requiring it when we passed the Climate and Equitable Jobs Act in 2021 and continuing through years of workshops and the recent regulatory proceeding. We’re encouraged to finally see real progress. While work remains before Illinois families can benefit from these programs, we remain committed to helping make them a reality,” said MeLena Hessel, Midwest Deputy Program Director at Vote Solar.
To learn more about the EEUP, visit the ICC’s website.
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