MNRE has extended a limited ALMM List-II exemption for net-metering and open-access renewable projects through 31 December 2026. Eligible projects may commission during this window without using solar cells enlisted under ALMM List-II. This is not a blanket rollback: the broader domestic-cell policy remains in force, and projects commissioning after the window should plan for List-II-compliant cells unless MNRE issues a further controlling order.
The 18 July 2026 decision materially changes the procurement guidance published when this article first appeared. C&I rooftop and open-access buyers should recheck module eligibility, commissioning schedules and EPC price assumptions rather than relying on the earlier 1 June deadline.
Key takeaways
- Relief window: net-metering and open-access renewable projects can commission without ALMM List-II-compliant cells until 31 December 2026.
- Scope is limited: MNRE says there is no blanket extension for every solar project.
- ALMM List-I is separate: the July relief concerns List-II solar cells; buyers must still verify all applicable module and tender requirements.
- Practical effect: eligible C&I projects may use available module inventory containing non-List-II cells during the window, subject to the controlling project and procurement rules.
- From 1 January 2027: buyers should contract on the assumption that List-II cell compliance will apply to these categories unless a later official order changes the position.
- Do not use the exemption as a schedule shortcut: commissioning, DISCOM approvals, metering and open-access readiness must all be planned realistically.
What changed on 18 July 2026?
MNRE announced a limited transition window for two project categories:
- net-metering projects; and
- open-access renewable energy projects.
These projects can now commission with an exemption from the ALMM List-II requirement for solar PV cells until 31 December 2026. The earlier dispensation for these segments had ended on 31 May 2026, when List-II implementation began on 1 June.
The July decision replaces the immediate need for project-by-project relief for these two broad segments during the stated window. It was framed as a transition measure to protect existing investments and module inventories while domestic approved-cell capacity continues to increase.
What are ALMM List-I and List-II?
The Approved List of Models and Manufacturers is administered by the Ministry of New and Renewable Energy.
| List | Covers | Why buyers care |
|---|---|---|
| ALMM List-I | Solar PV module models and manufacturers | Confirms which module models and manufacturers are enlisted for projects where List-I applies |
| ALMM List-II | Solar PV cells and manufacturers | Adds an upstream domestic-cell sourcing requirement for projects within its scope |
A module can be manufactured in India while using cells from a source that is not enlisted under List-II. That is why buyers must ask for both the module's List-I status and, where required, evidence for the cells used in the supplied batch.
Which C&I projects receive the December 2026 relief?
The official policy announcement identifies net-metering and open-access renewable energy projects. Those categories cover a large share of commercial and industrial solar procurement:
- a factory rooftop project exporting surplus energy under an approved net-metering arrangement;
- an off-site third-party open-access solar PPA;
- a captive or group-captive renewable project using open access; and
- other projects whose controlling approvals place them within the stated categories.
Project labels alone are not enough. The EPC contractor, developer and buyer should verify the applicable MNRE order, tender conditions, subsidy or DCR requirements, DISCOM approval and commissioning evidence for the specific project.
Projects outside net metering and open access should not assume that the exemption applies.
Does the relief permit imported modules?
The July 2026 relief is specifically about ALMM List-II solar cells. It should not be read as a general waiver of ALMM List-I, Basic Customs Duty, domestic-content requirements, tender specifications or subsidy conditions.
A compliant procurement check should separately answer:
- Is the module model and manufacturer enlisted under List-I where required?
- Are the cells enlisted under List-II, or does the project fall within the temporary exemption?
- Does the tender, PPA, subsidy or financing document impose a stricter condition?
- Can the supplier prove the bill of materials and batch identity?
- Will commissioning occur within the applicable relief period?
What does this mean for rooftop projects under net metering?
For eligible C&I rooftops, the extension can reduce near-term procurement pressure. A project commissioning by 31 December 2026 may be able to use modules made with non-List-II cells, even though the broader cell-localisation rule began on 1 June.
However, a signed EPC order is not the same as commissioning. Buyers should work backwards from the date on which the project can be documented as commissioned under the applicable DISCOM and regulatory process.
A realistic schedule should include:
- structural and electrical design;
- module and inverter procurement;
- DISCOM application and technical feasibility;
- protection, metering and synchronization work;
- inspection and testing;
- corrective work after punch-list inspection; and
- final commissioning documentation.
See our net-metering application guide and DHBVN net-metering guide for Haryana industries for the approval steps that can affect schedule.
What does it mean for open-access solar?
Open-access projects can also use the transition window, but their commercial analysis is wider than module sourcing. The buyer and developer must still manage:
- connectivity and transmission readiness;
- state open-access approval;
- captive or group-captive compliance where applicable;
- scheduling, metering and energy accounting;
- banking restrictions;
- transmission and wheeling losses;
- cross-subsidy and additional surcharge exposure; and
- PPA change-in-law provisions.
The cell exemption may help near-term procurement, but it does not remove these state-level risks. Read our open-access solar guide, group-captive guide and state comparison for open-access solar.
Should a buyer choose non-List-II cells to save money?
Not automatically. The choice should be based on total project risk, not only today's module quote.
| Question | Why it matters |
|---|---|
| Can the project commission by 31 December 2026? | A delayed project may cross into the compliance period |
| Is the supplier's batch traceable? | Documentation reduces acceptance and lender disputes |
| What does the EPC contract promise? | The contractor should own compliance with the agreed specification and law |
| Is financing conditional on domestic-cell compliance? | Lenders may impose requirements beyond the general exemption |
| Will the project be expanded or partly commissioned? | Treatment can depend on the documented commissioning scope |
| Is the price saving worth replacement or delay risk? | A cheap module is not cheap if the project becomes ineligible or late |
For projects close to year-end, a buyer may prefer List-II-compliant cells even when temporary relief is available. That removes deadline exposure and may simplify financing or future due diligence.
What should be added to the EPC or PPA documents?
C&I buyers should ask counsel and the technical adviser to make the compliance allocation explicit. Useful provisions include:
- a precise definition of applicable ALMM requirements;
- supplier evidence for module model, manufacturer and cell source;
- batch-level traceability and document-retention obligations;
- a warranty that equipment complies on the relevant supply and commissioning dates;
- a replacement obligation for non-compliant equipment;
- schedule responsibility where a delay changes the compliance requirement;
- change-in-law treatment after contract signing; and
- clear consequences for lost net-metering, open-access or financing eligibility.
Our solar EPC contract clauses guide and EPC quote review guide provide a broader procurement checklist.
C&I buyer decision checklist
Before issuing a purchase order or approving a module substitution:
- Download the latest controlling MNRE notice and current ALMM lists.
- Classify the project as net metering, open access or another category.
- Confirm whether any tender, subsidy, state or lender rule is stricter.
- Establish the latest credible commissioning date.
- Obtain the proposed module and cell details in writing.
- Compare List-II and non-List-II offers on delivered price, warranty, bankability and schedule.
- Allocate compliance and delay risk in the EPC contract or PPA.
- Keep invoices, serial numbers, manufacturer declarations and commissioning records.
- Recheck official notices before dispatch and before commissioning.
Frequently Asked Questions
What is the new ALMM List-II deadline for net-metering projects?
Eligible net-metering projects can commission without ALMM List-II-compliant solar cells until 31 December 2026 under MNRE's limited July 2026 transition window.
Does the exemption apply to open-access solar projects?
Yes. MNRE's announcement covers open-access renewable energy projects as well as net-metering projects through 31 December 2026.
Is ALMM List-II cancelled?
No. MNRE says the broader policy remains unchanged and there is no blanket extension. The relief is limited to specified project categories and dates.
Does the extension waive ALMM List-I for modules?
No. The announced relief concerns ALMM List-II solar cells. Buyers must separately verify List-I, tender, DCR, subsidy and other applicable requirements.
What happens to a project commissioning after 31 December 2026?
It should plan to use List-II-compliant cells where the rule applies, unless a later official MNRE order changes the requirement. Contracts should allocate the risk of schedule slippage across the deadline.
Should a factory rush commissioning before year-end?
No. The extension is useful only if the project can be safely completed, tested and documented. Rushed electrical work or incomplete approvals can create larger safety, operational and compliance risks than any module saving.
Sources
- MNRE current notices and ALMM updates — official portal
- India extends solar-cell sourcing relief for open access and net metering — Economic Times, 18 July 2026
- Centre extends non-ALMM solar-cell sourcing relief — Hindu BusinessLine, 19 July 2026
- MNRE extends List-II exemption to 31 December 2026 — Renewable Watch, 21 July 2026
This is a practical policy summary, not legal advice. MNRE notices, project-specific tenders, subsidy conditions and state approvals can impose additional requirements. Verify the controlling documents for the specific project before procurement.
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