Direct answer: Delhi’s 15 April 2026 proposal would remove the rule that effectively restricted green energy open access to consumers connected at 11 kV or above. If finalized in the form published, an LT consumer could qualify at 100 kW or more, including through aggregation of multiple connections in one distribution licensee’s area. However, this is a draft First Amendment, not a final regulation. An LT consumer should not contract, invest or claim eligibility solely on the draft until DERC publishes a final amendment and the relevant DISCOM confirms the operating procedure.
Key Takeaways
- DERC published the Draft Green Energy Open Access First Amendment Regulations, 2026 on 15 April 2026.
- The proposal deletes the 11 kV eligibility barrier while retaining the 100 kW threshold for non-captive consumers.
- Multiple connections may be aggregated only when they belong to the same consumer and fall within one DISCOM’s area of supply.
- Captive consumers are not subject to the 100 kW minimum under the underlying framework.
- Eligibility does not guarantee spare network capacity, economical charges, metering approval or scheduling clearance.
- As of the article’s 11 July 2026 update, businesses should treat the amendment as draft and verify that no final notification has superseded it.
What exactly did DERC propose on 15 April 2026?
DERC’s draft First Amendment targets a narrow but commercially important eligibility issue in the Delhi Electricity Regulatory Commission (Terms and Conditions for Green Energy Open Access) Regulations, 2024. The existing text linked eligibility to both a minimum load and a voltage condition. The 2026 draft proposes removing the 11 kV condition, opening a possible route for qualifying low-tension connections.
DERC listed the draft and public notice on its Draft Regulations page. Consultation does not create an enforceable entitlement; only a final notified amendment can change the 2024 regulations.
Who could qualify if the draft becomes final?
The proposed eligibility logic can be read as follows.
| Consumer situation | Threshold under proposed wording | Important qualification |
|---|---|---|
| One non-captive connection | 100 kW or more | LT would not be excluded merely because voltage is below 11 kV |
| Multiple non-captive connections | Aggregate 100 kW or more | Same consumer and one DISCOM area of supply |
| Captive consumer | No minimum load stated | Captive status must satisfy applicable Electricity Rules and evidence requirements |
| Connections across two DISCOM areas | Cannot be combined for this test | Evaluate separately within each licensee’s area |
| Consumer below 100 kW without captive route | Not eligible under this threshold | Do not assume another customer’s qualification applies |
“Aggregation” should not be read as permission for unrelated companies or sites to pool demand casually. Ownership, consumer identity, account records and DISCOM geography must support the aggregation. Corporate groups should obtain a written interpretation where legal entities differ.
For a broader foundation, see the open access solar guide and the comparison of CAPEX, OPEX and open access models.
Does 100 kW automatically secure open access?
No. The threshold is an entry condition, not an approval. The nodal agency and utilities still assess connectivity, sanctioned load, metering, capacity, scheduling, energy accounting and procedural compliance. An eligible consumer may still face a network constraint or uneconomic landed tariff.
The applicant also needs a viable green source, contract and delivery arrangement. Charges can include transmission, wheeling, losses, SLDC fees, cross-subsidy surcharge and additional surcharge, depending on the transaction and exemptions. Banking or settlement matters because daytime generation and facility demand rarely match.
Do not use the 100 kW figure as a solar plant sizing rule. Contract demand, sanctioned load, interval consumption, daytime load and allowed drawal are different variables. A load-data study should precede procurement; the factory solar sizing guide explains the demand-side analysis.
How should an LT consumer prepare before the rule is final?
A sensible preparation process avoids irreversible commitments while preserving speed.
| Step | What to prepare | Why it matters |
|---|---|---|
| 1. Confirm accounts | Latest bills, sanctioned load, voltage, consumer name and DISCOM | Tests individual or aggregated eligibility |
| 2. Map consumption | At least 12 months of bills and interval data where available | Shows daytime absorption and seasonal variation |
| 3. Choose transaction | Third-party, individual captive or group captive | Determines surcharge exposure and compliance |
| 4. Request feasibility | Connection point, network voltage, metering and capacity | Eligibility alone does not establish deliverability |
| 5. Build landed cost | Energy price plus every charge, loss and tax | Prevents comparison against retail tariff using an incomplete number |
| 6. Add conditions precedent | Final regulation, approval and acceptable charges | Protects the buyer while the amendment remains draft |
A term sheet can be negotiated, but it should clearly condition effectiveness on final law and approvals. Avoid non-refundable deposits justified only by the draft. Ask the supplier to show which party carries curtailment, deviation, change-in-law and delayed-approval risk.
How does the captive exception work?
The DERC framework states no minimum load limit for captive consumers, but “captive” is a legal status, not marketing shorthand. The project and users must satisfy the ownership and annual consumption tests under the Electricity Rules, including the rules applicable to group captive structures. Failure can expose consumption to cross-subsidy surcharge and create a substantial reconciliation liability.
A Delhi buyer considering group captive supply should review equity, voting rights, consumption allocation and annual monitoring. Our group captive 26% equity guide provides context, but project documents and current law control.
The no-minimum provision does not erase application, network, scheduling or metering requirements.
What costs should a Delhi consumer model?
Start with the delivered or ex-bus energy price, then add transmission and wheeling charges and losses, SLDC fees, deviation exposure, banking treatment, reactive energy, metering, surcharges, duty and taxes. Apply exemptions only after confirming the legal route and effective order.
Model monthly and 15-minute outcomes, not only an annual rate. Noon surplus cannot automatically offset evening consumption. Compare cost with the avoidable DISCOM bill; fixed or demand charges may remain. Test lower generation, curtailment, escalation, delay and loss of captive status.
What should buyers verify after a final notification?
First, compare the final clause word for word with the draft. DERC may retain, revise or abandon the proposed deletion. Second, check the effective date and any transition provision. Third, obtain the latest application procedure, forms, fees and nodal-agency instructions. Fourth, ask the local DISCOM how it will handle LT metering, communication equipment, energy accounting and aggregated accounts.
Finally, confirm whether any later tariff order changes the open access charges used in the business case. A final eligibility amendment would not freeze commercial charges. Keep a dated approval file containing the regulation, procedure, tariff orders, feasibility communication and signed agreements.
FAQ
Is Delhi green open access available to a 100 kW LT consumer today?
The 15 April 2026 draft proposes that result, but the draft itself is not legal clearance. Verify a final DERC notification and obtain the applicable approval before relying on it.
Can several meters be combined to reach 100 kW?
The proposed wording permits aggregation for multiple connections of the same consumer within the same distribution licensee’s area. Connections across different DISCOM areas should not be combined for the threshold.
Does an LT consumer need to upgrade to 11 kV?
The draft would remove 11 kV as an eligibility barrier. A utility may still identify technical works or a voltage change through its feasibility study; that is a site-specific network decision.
Is there a minimum load for captive green open access?
The regulatory framework states no minimum load for captive consumers. The consumer must still prove valid captive status and satisfy procedure, metering and network requirements.
Will cross-subsidy surcharge apply?
It generally depends on transaction structure. Valid captive consumption receives statutory treatment different from third-party supply, but the facts and annual captive compliance must support the exemption.
Does eligibility guarantee savings?
No. Savings depend on energy price, charges, losses, settlement, retained DISCOM charges and the facility’s load shape. Build a complete landed-cost model before signing.
When should a company submit its application?
Prepare documents now, but follow the effective regulation and current procedure at filing. Ask DERC or the relevant DISCOM to confirm status if no final amendment is visible.
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