Direct answer
On 26 August 2026, the Haryana Electricity Regulatory Commission (HERC) ruled in Petition No. 34 of 2026 that renewable energy developers and consumers can pursue green energy banking applications in parallel with Long-Term Open Access (LTOA) approval, rather than waiting for LTOA clearance first — a process that alone takes 60-90 days in Haryana. The order also directed relief from repetitive documentation demands. Both DHBVN and UHBVN, Haryana's two discoms, are bound as respondents.
TL;DR: if you are planning an open-access solar project in Haryana, banking no longer sits behind a completed LTOA approval in the approval queue — file both together, and expect lighter paperwork. This shortens the timeline for group-captive and third-party solar projects across Faridabad, Gurugram, Panipat and the rest of the state.
What the case was about
The petition was jointly filed by the Distributed Solar Power Association (DISPA) and seven clean-energy special purpose vehicles — CMES Power 2 and six Clean Max SPVs. Their complaint targeted Annexure-III of the HERC (Green Energy Open Access) Regulations, 2023, which in practice required developers to secure LTOA approval before even submitting a banking application.
That sequencing created a compounding delay. LTOA approval takes roughly 60-90 days. During that window, power injection and transmission-and-wheeling liabilities begin once approval lands, but banking — the mechanism that lets a generator deposit surplus renewable energy with the grid and withdraw it later — remained pending until a separate application was examined, approved and formalised. For a factory whose solar plant generates more than it consumes in some hours, un-banked surplus is settled at unfavorable rates, so every month of banking delay is a direct financial loss.
The petitioners also challenged documentation requirements: original balance sheets, specific chartered accountant certifications, detailed Memorandum and Articles of Association validations, and repeated board resolutions for what are often the same applicant entities.
What HERC decided
DHBVNL and UHBVNL opposed the petition on maintainability and argued that HVPNL — the state's open-access nodal agency — was a necessary party. HERC rejected both objections:
- Jurisdiction confirmed. The Commission held it has authority under Sections 86(1)(e), (f) and (k) of the Electricity Act, 2003 and its Conduct of Business Regulations to address implementation difficulties and relax procedural requirements — without rewriting the substantive regulations.
- HVPNL not required. Relying on official communication confirming that DHBVNL and UHBVNL are the designated nodal agencies for receiving and processing banking requests, HERC found HVPNL was neither a necessary nor a proper party.
- Procedural relief granted. The order clears the path for banking applications to proceed alongside LTOA applications, and directs relaxation of the challenged documentation burden.
The Commission was careful to note it was not amending the substantive banking rules — banking periods, charges and settlement under the 2023 regulations remain in force. What changed is the administrative sequence and paperwork load around them.
Why this matters for Haryana industrial solar buyers
Haryana is one of North India's most active open-access markets because industrial tariffs are high and the state hosts dense manufacturing belts — Faridabad, Gurugram, Manesar, Bhiwadi-adjacent Rewari, Panipat, Karnal and Hisar. For buyers in these belts, the order has three practical effects:
- Faster bankable timelines. Parallel processing can compress weeks off the approval chain between signing a group-captive or third-party PPA and the plant's first banked settlement. For a 1-5 MW industrial solar project, that accelerates the point at which surplus generation stops being a penalty and starts being a credit.
- Lower transaction friction. Documentation relaxation reduces the legal and administrative overhead that particularly burdens mid-size factories and SPV structures — the segment that most group-captive projects in Haryana actually serve.
- A pro-open-access signal. This is the second recent HERC order strengthening open access: in June 2026, HERC ordered full open-access approval for Jindal Stainless' 100 MW RTC renewable procurement for its Hisar plant, rejecting the utilities' blanket summer restrictions. A consistent regulatory posture reduces the perceived risk of long-term renewable contracts in the state.
For a primer on the framework this order sits within, see our green energy open access rules guide; for Haryana-specific charges and banking treatment, see the Haryana open access charges guide (FY 2026-27).
How banking fits your project economics
Banking determines what happens to energy your plant exports. Under Haryana's framework, banked energy can generally be withdrawn within the applicable billing cycle — with restrictions during designated ToD peak periods — but is not carried forward beyond the cycle, and banking charges apply per HERC regulations. A well-sized rooftop plant for a daytime-load factory (two-shift manufacturing, cold storage, textile processing) minimises exports, making banking a safety valve rather than the core value driver.
If your load profile is evening-heavy, the honest comparison is not rooftop solar versus banking — it is on-site solar sized to daytime load, plus a group-captive open-access supply for the balance. Our group captive solar guide explains the 26% equity structure and how landed tariffs compare, and the BESS arbitrage guide covers storage alternatives for NCR industrial ToD tariffs.
What to do now
- Applications in progress: if your LTOA is pending and you assumed banking would only start after, file the banking application now and cite Petition No. 34 of 2026.
- New projects: budget the approval chain with parallel banking — and hold your EPC to the real critical path: feasibility, CEIG approval, and net metering or open-access energy accounting setup.
- Existing plants: if banking applications were rejected or stalled on Annexure-III grounds in the past year, re-filing is worth a conversation with your open-access consultant.
FAQ
What is green energy banking in Haryana?
Banking lets an open-access renewable generator deposit surplus energy injected into the grid and withdraw an equivalent amount later within the billing cycle, instead of that surplus being settled at the dump tariff. Banking charges apply, withdrawal is restricted during designated ToD peak windows, and unused banked energy lapses at the end of the cycle under the HERC (Green Energy Open Access) Regulations, 2023.
What did HERC decide in Petition 34 of 2026?
HERC held that it can relax procedural requirements around green energy banking under its Electricity Act powers, cleared the way for banking applications to be filed in parallel with LTOA applications rather than after LTOA approval, and directed relief from repetitive documentation requirements. DHBVNL and UHBVNL are the nodal agencies for banking requests; HVPNL was held not to be a necessary party.
Does the order change banking charges or banking periods?
No. The order addresses procedural sequencing and documentation. Substantive terms — banking charges, billing-cycle treatment, ToD withdrawal restrictions — remain governed by the 2023 regulations and applicable HERC orders.
Does this apply to net-metered rooftop solar below 100 kW?
No. Green energy open access — and therefore this banking framework — applies to consumers meeting the open-access threshold (100 kW contract demand under the central Green Energy Open Access Rules framework). Smaller rooftop systems under net metering follow HERC's net-metering regulations instead, where surplus is settled at the applicable rates rather than through banking.
How long does open access approval take in Haryana now?
LTOA approval has typically taken 60-90 days; the banking step can now run in parallel rather than adding a further sequential wait after approval. Actual timelines still depend on application quality, grid studies for the specific substation, and discom processing — but the compound delay the petitioners demonstrated is no longer the mandated structure.
Sources
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