The Ministry of New and Renewable Energy (MNRE) has issued an important clarification dated 4 August 2026 on the applicability of ALMM List-II for solar PV cells.
The clarification brings much-needed clarity for solar developers, EPC contractors, government agencies and C&I consumers—particularly for projects transitioning to the domestic cell-listing framework.
But there is one point that should not be misunderstood:
There is no blanket exemption from ALMM List-II.
Whether List-II applies depends on several factors, including the project structure, bidding date, tender conditions and, in certain cases, the commissioning date.
What About Projects Commissioned by 31 December 2026?
For Net-Metering and Open Access projects commissioned on or before 31 December 2026, compliance with ALMM List-II for solar cells is exempt.
However, this does not mean that ALMM requirements disappear completely.
ALMM List-I for solar PV modules continues to apply.
MNRE's earlier official notice dated 18 July 2026 describes this as a specific commissioning window—not a general extension or permanent exemption.
For projects relying on this window, the commissioning timeline therefore becomes an important part of procurement and compliance planning.
A Significant Clarification for Behind-the-Meter Projects
One of the more important points in the latest clarification concerns private Behind-the-Meter solar installations used exclusively for captive consumption.
For consumers other than Government entities and PSUs, both ALMM List-I and List-II have been stated to be inapplicable to qualifying projects.
This distinction is particularly relevant for C&I solar projects, where the project structure can directly affect the applicable regulatory requirements.
Government and Bid-Based Projects Need More Care
Government projects and competitively bid projects require closer examination.
Depending on the bid submission date, certain projects may continue to fall under exemption provisions. At the same time, if the tender documents specifically required the use of ALMM List-II-compliant cells, those contractual requirements may continue to apply.
This means EPCs should not rely only on the latest general ALMM notification.
The tender document itself needs to be reviewed.
ALMM and DCR Are Not the Same
Another important clarification from MNRE is the distinction between ALMM and Domestic Content Requirement (DCR).
An exemption from ALMM List-II does not automatically remove any DCR obligation applicable under an MNRE scheme.
If a particular scheme requires DCR, that requirement continues independently.
In simple terms:
ALMM exemption ≠ DCR exemption.
What Should EPCs and Developers Check?
The question is no longer simply:
“Is ALMM List-II applicable to my project?”
The better approach is to ask:
- What is the project mechanism?
- Is it Net-Metering, Open Access or Behind-the-Meter?
- When was the project bid?
- What does the tender document specify?
- Is the project for captive consumption?
- Is the consumer a Government entity/PSU or a private entity?
- Is there a DCR requirement under the applicable scheme?
- Most importantly, when will the project actually be commissioned?
For projects targeting the 31 December 2026 commissioning window, procurement strategy and commissioning schedules should therefore be considered together.
A delay in commissioning may have regulatory consequences—not just project-management consequences.
The EPC Takeaway
The latest MNRE clarification provides relief in specific situations, but it should not be interpreted as a blanket relaxation of ALMM List-II.
For developers and EPC companies, the safest approach is to evaluate project mechanism + bid date + tender conditions + commissioning date + DCR requirements before finalising module and cell procurement.
Source: MNRE Office Memorandum No. 283/54/2026-GRID SOLAR dated 4 August 2026; MNRE ALMM notifications and related clarifications.
