ALMM List-II Exemption Window for Net Metering & Open Access

Qbits warranty and service terms: Qbits public datasheets describe an expandable warranty but do not define a universal duration, remedy, registration deadline, service SLA, or exclusions. Obtain the current written terms for the exact model and sale before relying on a headline claim.

ALMM and inverter compliance: MNRE’s current ALMM page publishes solar PV module and cell lists, not an inverter list. Verify the inverter’s exact model documents and applicable scheme or DISCOM requirements separately.

Anyone managing a net-metering or open-access solar project through the second half of 2026 has been watching one date more closely than any other: the point at which the ALMM List-II solar cell requirement becomes unavoidable. The Ministry of New and Renewable Energy has now drawn that line clearly. The ALMM List-II exemption for these project categories runs until 31 December 2026, and there is no blanket extension beyond it. For EPCs and commercial developers, that turns a vague policy anxiety into a concrete commissioning deadline that every live project must now be measured against.

Direct answer. The ALMM List-II exemption gives net-metering and open-access renewable energy projects a limited window to commission without sourcing solar cells from ALMM List-II. Any such project commissioned on or before 31 December 2026 keeps the exemption; projects commissioned from 1 January 2027 must use ALMM List-I modules built on ALMM List-II cells. The ministry has ruled out a blanket extension, so the date is best treated as a hard commissioning target managed through the 4-Gate ALMM List-II Commissioning Check.

Read the official notification. The full MNRE Office Memorandum No. 283/53/2026-GRID SOLAR, dated 18 July 2026, sets out the exemption window in the ministry’s own words. Keep a copy on the project file for DISCOM queries. Download the ALMM List-II exemption OM (PDF)

What the ALMM List-II Exemption Window Actually Changes

The rule that came into force on 1 June 2026 was straightforward on paper: net-metering and open-access renewable energy projects commissioned on or after that date had to source modules from ALMM List-I and cells from ALMM List-II. In practice, domestic cell supply was not ready for that switch across every technology, and developers with modules already built on non-approved cells faced stranded inventory. The July 2026 office memorandum resolves the near-term pressure without abandoning the policy: it extends the exemption to 31 December 2026 for the two named categories, then holds the line.

The chronology matters, because the current position is the product of several notifications building on one another rather than a single announcement.

Get the source document. The 18 July 2026 memorandum supersedes the 25 May 2026 order and confirms the 31 December 2026 commissioning window in full. Download the full memorandum from MNRE (PDF)

The single most important shift is psychological as much as regulatory. Before July, a developer holding non-compliant cell inventory faced an immediate wall on 1 June. Now there is a defined runway to 31 December 2026, which is enough to commission projects that are genuinely close to completion. The ministry has separately clarified how the cut-off reads for different site types, including that rooftop projects on government buildings commissioned before 1 June 2026 stay exempt while later ones must comply, as reported by Saur Energy. What has not changed is the destination. The ministry framed the window as a way to protect investments already made in module inventory while giving domestic cell manufacturers demand certainty to scale, and it was explicit that there would be no blanket extension of the policy for all solar projects. According to the Ministry of New and Renewable Energy, strengthening domestic manufacturing remains the governing priority behind the whole sequence.

ALMM and inverter compliance are separate checks

Most confusion around this policy comes from mixing up three separate ALMM tracks. Getting the vocabulary right is the difference between a compliant bill of quantities and a rejected connection.

ALMM List-I: Solar Modules

List-I is the approved list of solar PV modules and their manufacturers. A module must come from an enlisted maker to be accepted for covered projects.

ALMM List-II: Solar Cells

List-II is the newer track and the subject of the exemption window. It is the approved list of solar PV cells and their manufacturers. The intent is to close a loophole: a module could sit on List-I while being built on imported cells, which undercut the domestic-manufacturing goal. List-II requires the cell inside an approved module to come from an approved cell maker. This is what makes the requirement harder to meet, because India’s cell manufacturing base is much smaller than its module base, a gap examined in detail in the import duty and domestic manufacturing picture.

Inverters: no ALMM list

MNRE’s ALMM page publishes List-I for modules and List-II for cells. It does not publish an inverter list, so an inverter is verified separately through its exact model documents and the applicable scheme or DISCOM requirements.

Who Qualifies: Net Metering and Open Access Projects Explained

The exemption is category-specific. It applies to two clearly named project types, and reading the fine print of your own project category is the first compliance step, not an afterthought.

• Net-metering projects: Grid-connected systems where the consumer offsets their own consumption and exports surplus to the DISCOM under a net-metering arrangement. This covers most residential rooftops and a large share of commercial and industrial rooftop systems. If you are unsure how your connection is classified, the net-metering application process walks through how the category is assigned.
• Open-access projects: Larger commercial and industrial procurement where power is generated at a remote plant and wheeled to the consumer through the grid. These are the projects where C&I payback and IRR modelling drives the investment decision, and where a shift in cell sourcing can move the capital cost enough to matter.
• What is not covered here: Utility-scale central tenders and several other categories operate under their own bid conditions and were not the subject of this specific relief. A project that assumes the net-metering exemption applies when it is actually contracted under a different framework is exposed to a compliance surprise at connection.

The reason the ministry singled out these two categories is that they carry the highest volume of near-complete projects held up by the cell requirement. The difference between gross metering and net metering also matters here, because the connection type your project falls under determines which set of rules and deadlines you are actually subject to. Do not infer eligibility from the technology on the roof; confirm it from the connection agreement.

The 4-Gate ALMM List-II Commissioning Check

Knowing the deadline is not the same as being ready for it. Projects miss compliance windows not because the team ignored the date, but because no single owner held responsibility for the sequence of checks that the date implies. The following framework assigns that responsibility across four gates, each with a clear pass condition.

The 4-Gate ALMM List-II Commissioning Check

1. Category gate: Confirm in writing that the project is contracted as net-metering or open-access, and that the exemption therefore applies. Pull the connection agreement or bid condition, not the sales proposal. A project misclassified at this gate fails every gate after it.
2. Commissioning-date gate: Fix a target commissioning date with real margin before 31 December 2026, not on it. Treat mid-December as the effective cut-off to absorb inspection delays, DISCOM scheduling, and the year-end backlog every installer will be fighting at once.
3. Sourcing gate: Decide the cell-sourcing plan for anything that might slip past the window. If a project could realistically commission in early 2027, procure ALMM List-I modules built on ALMM List-II cells from the outset rather than gambling on the exemption. Carrying two procurement paths is cheaper than a stranded system.
4. Relief-evidence gate: For projects genuinely close but at schedule risk, assemble the case-by-case extension file now: dated procurement invoices, installation photographs, and site-progress records. A discretionary extension is only as strong as the evidence behind it.

The framework works because it forces the decision early. Most commissioning failures on this deadline will come from projects that treated 31 December 2026 as a distant certainty in July and discovered a category or sourcing problem in November, when there was no time left to fix it. Running the four gates at project kickoff, and again at the 60-day mark, turns a policy risk into a managed schedule item.

Why MNRE Refused a Blanket Extension: The Cell-vs-Module Capacity Gap

To understand why the ministry held the deadline instead of removing it, look at the numbers behind India’s cell and module manufacturing. The mismatch is the entire reason List-II exists, and also the reason a limited window made more sense than an open-ended one.

~193 GW vs ~31 GW. India’s approved solar module manufacturing capacity dwarfs its domestic solar cell capacity, which is the structural gap ALMM List-II is designed to close. Source: Mercom India, 2026.

The gap is sharpest in the dominant cell technology. Approved module capacity in TOPCon runs to roughly 172 GW, while domestic TOPCon cell capacity is only around 10 GW.

That imbalance is exactly what a cell-level rule exposes: modules can be built at scale, but not yet on domestically approved cells at the same scale. A blanket extension would have let approved modules keep drawing on imported cells indefinitely, removing the demand pull that new domestic cell lines need in order to justify their investment.

At the same time, the approved cell base is growing. The ministry has continued to enlist new capacity through successive revisions of the list.

30.3 GW. Total ALMM List-II enlisted cell capacity as of the seventh revision on 30 April 2026, boosted by newly listed heterojunction capacity. Source: MNRE ALMM Portal, 2026.

The demand side was equally loud. India installed 15.3 GW of solar in the first quarter of 2026, a sharp jump driven partly by developers racing to commission ahead of the cell deadline. That rush is a signal the ministry read carefully: the appetite to build is there, and a firm but reasonable window channels it toward domestic cells rather than letting it drain into imports. Manufacturers of standalone modules, who had already invested in inventory, pushed for protection, while cell manufacturers pushed against any softening of the rule, a tension covered in depth by Mercom India. The 31 December 2026 window is the compromise between those two camps.

What Happens to Projects Commissioned After 31 December 2026

The cleanest way to plan is to model both outcomes side by side: a project that commissions inside the window and one that slips past it. The commercial and compliance consequences diverge sharply.

Case-by-Case Relief: How to Apply Before the Window Closes

Separate from the blanket exemption window, the ministry has kept a discretionary route open for projects that were substantially progressed before the deadline. This is not automatic, and it is not a second blanket extension. It is an evidence-led application decided on the merits of each project.

The categories the ministry has signalled it will consider include projects where module installation is complete but commissioning is pending, and projects where effective steps toward implementation have already been undertaken. The common thread is demonstrable progress made in good faith before the rule bit. A project that had done nothing by the deadline has no standing to seek relief.

• Assemble dated evidence: Procurement invoices, delivery receipts, installation photographs with timestamps, and any DISCOM correspondence. The strength of the application is the strength of the paper trail behind it.
• Submit through the designated portal: Extension requests are routed through the national solar DCR portal with supporting documentation, rather than through informal channels. Treat it as a formal filing.
• Do not rely on relief as a plan: A discretionary extension is a fallback for genuine near-misses, not a substitute for hitting the commissioning date. Build the schedule to clear the window on its own, and keep the relief file as insurance.

Common Mistakes Developers and EPCs Make on the ALMM List-II Deadline

The failures on this deadline are predictable, which means they are preventable. Field experience across EPC and developer teams surfaces the same handful of errors, and each maps to a gate in the framework above.

• Confusing List-I, List-II, and the inverter list: Teams assume that because their modules are on List-I, they are compliant, and miss that the cell inside the module must trace to List-II from 2027. Verify all three tracks separately.
• Assuming the exemption covers every project category: The window is for net-metering and open-access projects specifically. A project contracted under a different framework may not qualify, and inferring eligibility from the roof rather than the connection agreement is a classic error covered when evaluating EPC bids.
• Treating 31 December as the commissioning date rather than the deadline: Aiming to commission on the last day leaves zero margin for DISCOM inspection delays and the year-end backlog. The commissioning-date gate exists precisely to prevent this.
• Letting inverter or balance-of-system procurement become the bottleneck: The cell rule gets all the attention, but a late inverter or a failed commissioning test can push a project past the window just as easily. Sound inverter procurement discipline protects the deadline.
• Not documenting progress for a possible extension: Projects that might qualify for case-by-case relief often cannot prove it because nobody kept dated records. Dated record-keeping should start on day one, not from the moment a project starts slipping.

For empanelled installers, there is an added dimension: a compliance miss on a net-metering project can affect standing with the DISCOM and, for PM Surya Ghar empanelled vendors, the broader relationship that underpins the whole book of business. The cost of a missed deadline is rarely limited to one project.

Where Qbits Fits

• Hybrid Inverters: Review current QBH model documents and confirm the exact battery, firmware, PV, backup-output, transfer, communication, warranty and project requirements in writing.
• C&I Solution: Commercial and industrial deployments where open-access timelines and the 31 December window intersect.
• Authorised Service Partners: Search the current directory, then confirm partner status, service scope, coverage, response process and commercial terms for the location.

Contact Qbits with the site, load, equipment and document details relevant to this guide. Confirm the responsible party, deliverable, commercial scope and response time after submission.

The ALMM List-II exemption window is a reprieve with a fixed end, not a change of direction. The ministry has been consistent that domestic cell manufacturing is the destination, and the 31 December 2026 date is the last stretch of runway for net-metering and open-access projects to commission on the old terms. Developers and EPCs who run the 4-Gate ALMM List-II Commissioning Check now, confirm their category, protect their commissioning date, plan their sourcing, and document their progress, convert a policy deadline into a managed schedule. The ones who wait until December to check will find the window, and every DISCOM inspection slot behind it, already full.

Sources and Official Notices

Every date, figure, and rule in this guide traces back to a primary MNRE notice or a named industry report. Verify the current position directly against these before acting on a live project, as the ministry updates the position through fresh notifications.

• MNRE Office Memorandum No. 283/53/2026-GRID SOLAR, dated 18 July 2026 (PDF): the primary notification establishing the limited exemption window till 31 December 2026 for net-metering and open-access projects.
• MNRE Approved List of Models and Manufacturers (ALMM) portal: the master page for ALMM List-I, List-II, and the enlisted cell capacity figures.
• MNRE Current Notices: where the 18 July 2026 notice on the limited exemption window till 31 December 2026 is published.
• MNRE notice: no blanket extension of ALMM List-II beyond 01.06.2026: the 25 May 2026 notice (OM 283/63/2025-GRID SOLAR) establishing the no-blanket-extension position and case-by-case relief.
• Business Standard: government extends exemption for net-metering and open-access RE projects till December: reporting on the 18 July 2026 extension.
• Mercom India: developers seek ALMM List-II extension, manufacturers push back: the module-versus-cell capacity gap and industry positions.
• Saur Energy: MNRE clarifies ALMM cell norms for rooftop solar on government buildings: clarification on how the cut-off reads for government-building rooftops.
• National DCR Portal (NISE): the designated portal for case-by-case commissioning extension requests.