MNRE ALMM List-II Clarification August 2026: Cell Exemptions

TL;DR — MNRE ALMM List-II Clarification, August 5 2026

On August 5 2026, India's Ministry of New and Renewable Energy (MNRE) issued an Office Memorandum clarifying exactly which solar projects must comply with the ALMM List-II domestic-cell mandate, and which remain exempt — closing weeks of ambiguity after the July 18 2026 notification.
Net-metering and open-access solar projects are exempt from the ALMM List-II (domestic cell) requirement if commissioned on or before December 31 2026, regardless of when the project was initiated. No NISE Solar DCR Portal application is needed. ALMM List-I (domestic modules) still applies.
Competitive-bidding projects are exempt if their bid submission deadline fell on or before August 31 2025 (and bids were live as of July 28 2025). Bids submitted after August 31 2025 must comply with ALMM List-II.
For commercial and industrial (C&I) rooftop buyers in Delhi-NCR, Haryana, Rajasthan, and UP, this means a net-metered or open-access plant commissioned in 2026 can still use imported-cell modules — but only through December 31 2026. From January 1 2027, compliance is mandatory for new commissioning.
Domestic cell capacity is scaling fast — ALMM List-II listed capacity reached 31.76 GW by July 22 2026 (per Mercom India), and Crisil projects domestic cells will meet roughly half of India's 60–65 GW demand in FY2026-27.
The bottom line: if your factory or warehouse is planning a rooftop solar plant in 2026, you have a confirmed window to commission with currently-priced modules — but your solar EPC company in India should still source ALMM List-I modules and prepare for full List-II compliance in 2027.

What the August 5 2026 Clarification Actually Says

The Approved List of Models and Manufacturers (ALMM) is MNRE's mandatory domestic-content framework for solar equipment. ALMM List-I covers modules and has been enforced for several years. ALMM List-II covers solar PV cells and took effect on June 1 2026, requiring that cells inside ALMM-listed modules also be manufactured in India. For full background on the original mandate, see our ALMM Mandate 2026 guide.

After the mandate kicked in, developers and commercial & industrial solar buyers raised dozens of representation requests asking MNRE to clarify edge cases: What about a project that started before June 2026 but commissions after? What about open-access farms? What about net-metering rooftops? Behind-the-meter captive plants? Government rooftops?

MNRE's August 5 2026 Office Memorandum answers these questions category by category. In short, the ministry confirmed there will be no blanket extension of ALMM List-II — but it granted specific, time-bound exemptions for the project categories where ongoing work would otherwise be disrupted.

The Exemption Categories, Explained

Category 1: Net-Metering and Open-Access Projects (the C&I sweet spot)

This is the category that matters most for Sun Wave's customers. MNRE clarified:

Any net-metering or open-access solar project commissioned on or before December 31 2026 is exempt from ALMM List-II for solar PV cells.
The exemption applies regardless of whether the project was initiated before or after July 18 2026 — the key date is commissioning, not project start.
Developers do not need to submit any application through the NISE Solar DCR Portal to claim this exemption.
ALMM List-I for solar PV modules continues to apply wherever relevant — so your modules must still be domestically manufactured and ALMM-listed.

MNRE also clarified that the term "Net Metering" includes Gross Metering, Net Billing, Net Feed-In, Virtual Net Metering, and Group Net Metering — but specifically excludes Behind-the-Meter (BTM) projects, which are handled separately (see Category 5 below).

Category 2: Competitive-Bidding Projects (utility and large C&I tenders)

For projects awarded through competitive bidding:

Bid submission deadline	ALMM List-II (cells) status
On or before December 9 2024	Exempt
December 9 2024 to July 28 2025	Follow tender terms — if the tender explicitly mandated ALMM List-II, that condition still applies
July 28 2025 to August 31 2025	Exempt
After August 31 2025	Must comply with ALMM List-II

The logic: MNRE's July 28 2025 amendment shifted the general cut-off date for ALMM List-II applicability from December 9 2024 to August 31 2025. The August 2026 clarification confirms this shift applies to the bid-submission window, and does not override conditions already written into tender documents during the interim period.

Category 3: PM Surya Ghar Residential Rooftop

Residential consumers opting for the "Give It Up" subsidy option under the PM Surya Ghar: Muft Bijli Yojana remain exempt from ALMM List-II for solar PV cells until March 31 2027, provided applications are submitted exclusively through the PM Surya Ghar National Portal. ALMM-listed modules are still required.

Category 4: Government Rooftop Projects

MNRE split government rooftops into two sub-cases:

Competitive-bidding government rooftops follow the same bid-deadline table as Category 2 above.

Government rooftop projects not awarded through competitive bidding: exempt if commissioned on or before December 31 2026; projects commissioned after that date must use ALMM List-II-listed solar PV cells.

Category 5: Behind-the-Meter (BTM) Captive Projects

For BTM solar plants established for captive consumption by private consumers or groups of consumers (excluding government entities and public sector enterprises), both ALMM List-I and ALMM List-II do not apply. This is a significant clarification for private industrial captive users — a behind-the-meter plant consumed entirely on-site by a private factory is outside the ALMM cell mandate entirely.

For government entities and PSEs operating BTM captive plants: projects commissioned on or before December 31 2026 must use ALMM-listed modules (List-I) but are exempt from ALMM-listed cells (List-II). Projects commissioned after December 31 2026 must use both ALMM-listed modules and cells.

Category 6: Domestic Content Requirement (DCR) — Unchanged

MNRE explicitly stated that the August 2026 clarification does not alter or dilute the Domestic Content Requirement provisions applicable under various government schemes. DCR obligations continue to be governed by their respective scheme guidelines, and the ALMM clarification should not be read as any relaxation of mandatory domestic module or cell use under DCR-based programmes.

Why MNRE Issued This Clarification Now

The August 5 2026 memo follows a July 18 2026 notification in which MNRE first extended the net-metering and open-access exemption — previously set to lapse on May 31 2026 — through December 31 2026. That July notification (reported by The Economic Times, The Hindu BusinessLine, Financial Express, and CNBC TV18) covered the core C&I relief but left implementation questions unanswered: Did developers need to apply through the NISE portal? Did it matter when the project started? Did it cover group net metering and virtual net metering?

The August 5 clarification resolves all of these. The practical driver, according to MNRE and industry reporting, is the gap between India's domestic cell manufacturing capacity and its module capacity. As of mid-2026:

Domestic solar cell capacity: approximately 30 GW operational, with ALMM List-II listed capacity at 31.76 GW as of July 22 2026 (Mercom India)
Solar module manufacturing capacity: approximately 193 GW under ALMM List-I, with 225 GW nameplate capacity overall
TOPCon cell capacity specifically: only around 10 GW domestic, versus nearly 172 GW of approved TOPCon module capacity — the sharpest mismatch

MNRE's stated rationale is that the extension protects investments already made by standalone solar module manufacturers (in the form of imported-cell inventory) while giving them time to shift sourcing toward ALMM List-II-enlisted cell manufacturers as domestic cell capacity "continues to rise steadily."

What This Means for C&I Solar Buyers in North India

Sun Wave's customers — factories, warehouses, and manufacturing plants across Delhi-NCR, Haryana, Rajasthan, and Uttar Pradesh — fall overwhelmingly into Category 1 (net-metering) or Category 5 (BTM captive). Here is what the clarification means for each model.

Net-Metered Rooftop Buyers (the majority of C&I projects)

If your factory rooftop solar plant will be commissioned on or before December 31 2026, you can proceed with currently-priced modules that use imported cells, provided the modules themselves are ALMM List-I listed. This is a real cost saving in the near term — imported-cell modules typically carry a 10–20% lower cell cost than fully domestic-cell modules, translating to roughly ₹1.0–1.5 per Wp on finished module pricing. On a 1 MW industrial rooftop, that is approximately ₹10–15 lakh.

However, the saving comes with a deadline. Any plant commissioned after December 31 2026 must use ALMM List-II-compliant modules (domestic cells). This means:

Projects in late-stage execution (engineering complete, modules ordered, installation underway) should prioritize commissioning before the year-end deadline to capture the exemption.
Projects in early planning (site survey, feasibility, quote evaluation) should plan for 2027 commissioning under full List-II compliance — and budget for the 3–6% module cost increase described in our solar EPC cost per MW guide.
RESCO/OPEX projects under a RESCO model should confirm with the developer whether the PPA tariff reflects pre- or post-December 2026 module pricing.

The most important action for any C&I buyer right now is to confirm the commissioning timeline with your EPC partner and decide whether to accelerate into the 2026 window or plan for 2027 compliance.

Open-Access Buyers

Open-access solar farms — off-site power procurement for large consumers — fall under the same December 31 2026 commissioning deadline. If your open-access PPA is tied to a solar farm commissioning in 2026, the developer can use imported-cell modules. For farms commissioning in 2027, expect landed tariffs to reflect the full List-II cost stack. Our solar open access state comparison tracks how this interacts with state-level open-access charges.

Group Captive Buyers

Group captive structures follow the open-access rules — the December 31 2026 commissioning deadline applies. The 26% equity ownership requirement and captive-use rules are unaffected by the ALMM clarification.

Behind-the-Meter Captive Buyers

If your factory operates a BTM solar plant for 100% on-site captive consumption (no export, no grid interaction beyond connection), and you are a private entity (not a government body or PSE), ALMM List-I and List-II do not apply. This is the most permissive category under the August 5 clarification. In practice, most C&I rooftop plants in Sun Wave's service area are net-metered rather than pure BTM, but BTM is increasingly attractive for plants sized below the sanctioned load where self-consumption is near-total.

How to Use the December 31 2026 Window Strategically

The exemption window is not a reason to delay a project — it is a reason to accelerate execution for projects that can realistically commission before the deadline. Here is a decision framework.

Step 1: Check Your Commissioning Feasibility

A typical 500 kW to 2 MW industrial rooftop project takes 8–12 weeks from contract signing to commissioning, assuming roof readiness, structural clearance, and DISCOM net-metering approval proceed on schedule. If you are reading this in August 2026 and have not yet signed an EPC contract, commissioning before December 31 2026 is achievable but tight. If you are in feasibility or quote-evaluation stage, plan for 2027 commissioning under full compliance.

Step 2: Lock Module Sourcing Now

For projects targeting 2026 commissioning, confirm with your solar provider in India that:

Modules are ALMM List-I listed (mandatory regardless)
Module manufacturer can deliver within your installation window
Cell origin is documented for your records (even though List-II is exempt through December 2026, traceability protects warranty and resale value)

Step 3: Accelerate Net-Metering Approval

The net-metering application and DISCOM approval process is often the longest lead-time item. In Haryana (DHBVN/DHBVNL), Rajasthan (RRECL/Discoms), and UP (UPCL/DISCOMs), approval timelines range from 30 to 90 days depending on sanctioned load and transformer feasibility. Starting the application now — in parallel with EPC contracting — is essential to hit the December 31 2026 commissioning target. See our DHBVN net-metering guide for the Haryana process.

Step 4: For 2027 Projects, Budget for Full Compliance

Projects commissioning January 1 2027 or later must use ALMM List-II-compliant modules. Budget a 3–6% module cost increase (roughly ₹10–15 lakh per MW) and restrict sourcing to vertically integrated Indian manufacturers — Waaree, Adani Solar, Premier Energies, ReNew, Vikram Solar, Goldi Solar, Tata Power Solar — who operate both cell and module lines. The silver lining: by 2027, domestic cell capacity is expected to have scaled meaningfully, with Crisil projecting cumulative cell capacity near 60 GW by end of FY2026-27, which should compress the domestic-vs-imported cell price gap.

The Broader Capacity Picture Behind the Exemption

MNRE's willingness to grant the December 31 2026 window reflects the real supply-chain reality. The numbers, verified from Mercom India, PV-Tech, and The Economic Times reporting in June–August 2026:

Metric	Figure	Source
ALMM List-II listed cell capacity (July 22 2026)	31.76 GW	Mercom India
Domestic cell capacity operational (mid-2026)	approximately 30 GW	The Economic Times
ALMM List-I module capacity (August 2026)	217.1 GW (217,107 MW)	PV-Tech
Solar module nameplate capacity	approximately 225 GW	The Economic Times
Domestic cell capacity projected FY2026-27 end	approximately 60 GW	Crisil (pv-magazine India)
C&I solar added in FY26	15 GW (of 44.61 GW total)	The Economic Times
Projected 2026 domestic cell demand	22–25 GW	Indian Solar Manufacturers Association

The takeaway: module capacity vastly exceeds cell capacity today, but cell capacity is scaling rapidly. The December 31 2026 exemption is a bridge to let that capacity come online without stalling the C&I segment — which contributed 15 GW of the 44.61 GW added in FY26, the single largest growth segment.

Sun Wave Technologies' Response to the August 2026 Clarification

As a focused commercial & industrial solar EPC company serving Faridabad, Delhi-NCR, Haryana, Rajasthan, and Uttar Pradesh, Sun Wave Technologies is implementing the August 2026 clarification as follows:

For clients commissioning in 2026: modules sourced from ALMM List-I listed manufacturers, with cell-origin documentation provided for traceability and warranty protection, capturing the imported-cell cost advantage where the project qualifies for the net-metering/open-access exemption.
For clients commissioning in 2027: full ALMM List-II-compliant module sourcing from vertically integrated Indian manufacturers (Waaree, Adani, Premier, ReNew, Vikram, Goldi, Tata Power Solar), with cell-level traceability documentation included as standard EPC scope.
For BTM captive clients: confirmation of BTM status and ALMM exemption documentation where applicable, while still recommending ALMM-listed modules for long-term warranty and resale value.
Net-metering application acceleration: parallel-track DISCOM approval processing to maximize the number of client projects commissioning within the December 31 2026 window.

For industrial buyers in Haryana, Rajasthan, or the broader Delhi-NCR belt evaluating a rooftop solar project, the August 2026 clarification creates a clear strategic choice: accelerate to commission in 2026 under the exemption, or plan for 2027 under full compliance. Sun Wave handles both paths with documented ALMM sourcing.

Frequently Asked Questions

What is the MNRE ALMM List-II clarification of August 5 2026?

The August 5 2026 Office Memorandum from MNRE clarifies which solar projects must comply with ALMM List-II (the domestic solar cell manufacturing requirement) and which remain exempt. The key outcome is that net-metering and open-access solar projects commissioned on or before December 31 2026 are exempt from the domestic-cell requirement, regardless of when the project was initiated. Competitive-bidding projects are exempt if their bid submission deadline was on or before August 31 2025. The clarification confirms there is no blanket extension of ALMM List-II, and ALMM List-I for modules continues to apply.

Does the December 31 2026 exemption apply to my industrial rooftop solar project?

If your industrial rooftop solar plant is net-metered (including gross metering, net billing, net feed-in, virtual net metering, or group net metering) and will be commissioned on or before December 31 2026, yes — it is exempt from the ALMM List-II domestic-cell requirement. You do not need to apply through the NISE Solar DCR Portal. However, your modules must still be ALMM List-I listed (domestically manufactured). If your plant commissions on or after January 1 2027, full ALMM List-II compliance is required.

What is the difference between ALMM List-I and ALMM List-II?

ALMM List-I is the Approved List of Models and Manufacturers for solar PV modules — it requires that modules used in eligible projects be manufactured in India. ALMM List-II is the equivalent list for solar PV cells — it requires that the cells inside those modules also be manufactured in India. ALMM List-I has been enforced for several years; ALMM List-II took effect on June 1 2026. The August 2026 clarification grants time-bound exemptions from List-II (cells) for specific project categories, while List-I (modules) continues to apply throughout.

Are behind-the-meter captive solar projects exempt from ALMM?

Yes, for private consumers and groups of private consumers. The August 5 2026 clarification states that both ALMM List-I and ALMM List-II do not apply to behind-the-meter (BTM) solar power plants established for captive consumption by private consumers or groups of consumers, excluding government entities and public sector enterprises. For government entities and PSEs, BTM projects commissioned on or before December 31 2026 must use ALMM-listed modules but are exempt from ALMM-listed cells; after December 31 2026, both apply.

Will my solar project cost more if I commission after December 31 2026?

Yes, typically by 3–6% on module cost. Projects commissioning after December 31 2026 that fall under the net-metering or open-access categories must use ALMM List-II-compliant modules with domestically manufactured cells. Indian-made cells currently carry a 10–20% premium over imported cells, translating to roughly ₹1.0–1.5 per Wp on finished modules, or approximately ₹10–15 lakh per MW of installed capacity. However, domestic cell capacity is scaling rapidly — Crisil projects cumulative cell capacity near 60 GW by end of FY2026-27 — which should narrow the price gap over time.

Do I need to apply through the NISE portal for the net-metering exemption?

No. The August 5 2026 clarification explicitly states that for net-metering and open-access projects commissioned on or before December 31 2026, developers do not need to submit any application through the NISE Solar DCR Portal to avail the exemption. The exemption is automatic based on the commissioning date. This supersedes the earlier case-by-case application process that had a June 30 2026 (later extended to July 23 2026) portal submission deadline.

Does the ALMM List-II clarification affect the PM Surya Ghar residential subsidy?

The ALMM List-II clarification confirms that residential consumers opting for the "Give It Up" subsidy under PM Surya Ghar: Muft Bijli Yojana remain exempt from ALMM List-II for solar PV cells until March 31 2027, provided applications are submitted through the PM Surya Ghar National Portal. ALMM-listed modules (List-I) are still required. The PM Surya Ghar scheme itself is residential and separate from the C&I focus of this clarification, but the extended cell exemption through March 2027 gives residential installers additional runway.

How does this clarification interact with state net-metering rules?

The ALMM List-II exemption is a central (MNRE) manufacturing-content rule and is separate from state-level net-metering regulations governed by State Electricity Regulatory Commissions. A C&I project must satisfy both: (1) the central ALMM exemption/compliance rules for modules and cells, and (2) the state net-metering rules for capacity caps, settlement mechanism, and DISCOM approval. In Haryana, for example, the DHBVN net-metering process and the HERC open-access surcharge framework apply alongside the central ALMM rules. Neither is overridden by the other.