ALMM List-II: What the Dec 2026 Window Means for C&I Solar

ALMM List-II: What the Dec 2026 Window Means for C&I Solar

Solar Policy & Regulation

If your company is evaluating rooftop solar in 2026, one regulation should be on your procurement checklist before you sign anything: ALMM List-II. It became one of the most consequential policy shifts in Indian solar this year, and it just changed again — on July 18, 2026, MNRE opened a limited relief window that directly affects when you should commission and what your project will cost.

ALMM List-II is a Ministry of New and Renewable Energy (MNRE) mandate requiring solar projects in notified categories to use modules built with domestically manufactured solar cells from MNRE's approved list. It came into force on June 1, 2026 — but under MNRE's order of July 18, 2026, net-metering and open-access projects can commission with exemption from List-II until December 31, 2026. From January 1, 2027, they too must comply.

Here's what CFOs, sourcing heads, and plant directors need to know - without the jargon.

What exactly is ALMM List-II?

ALMM List-II is the second tier of MNRE's Approved List of Models and Manufacturers. List-I, in force for years, approved solar modules. List-II goes a level deeper: it approves the solar cells inside those modules, and it requires them to be made in India.

The framework was announced in MNRE's office memorandum of December 9, 2024, and compliance became mandatory on June 1, 2026. After the rollout exposed a gap between domestic cell supply and demand, MNRE issued O.M. No. 283/53/2026-GRID SOLAR on July 18, 2026: while reiterating that there is no change in policy and no blanket extension, it provided a limited transition window allowing net-metering and open-access renewable energy projects to commission without List-II compliance until December 31, 2026. MNRE has been explicit that this is not a blanket extension: the window applies specifically to these two notified categories and does not extend generally to other solar projects.

The policy goal is straightforward: build a fully integrated domestic solar manufacturing chain rather than an assembly industry running on imported cells. MNRE has also proposed implementing a List-III for solar wafers from June 1, 2028.

Does ALMM List-II apply to my rooftop solar project?

It depends on how your project connects to the grid — and, now, on when it commissions. An important scoping point first: ALMM List-II applies only to projects that fall within the categories notified by MNRE. Your project's structure, grid connection, and commissioning date determine whether and when the requirement applies.

Within scope, but with a transition window until December 31, 2026:

  • Net-metering rooftop projects — many C&I rooftop installations use net metering and fall in this category

  • Open-access renewable energy projects, including group-captive structures

Projects in these two categories commissioned on or before December 31, 2026 may continue using existing solar cell supply chains, subject to the project's applicable tender and procurement conditions — projects awarded through bidding have historically been governed by separate bid-date rules. Projects commissioning from January 1, 2027 must use ALMM List-I modules built with List-II cells.

Within scope with no relief window:

  • Government-backed and subsidised solar projects (subject to their specific tender conditions and bid-date exemptions)

  • The transition window applies specifically to notified net-metering and open-access projects and does not extend generally to other categories, including utility-scale projects

Potentially outside scope:

  • Certain purely behind-the-meter captive projects may fall outside the notified categories depending on their connection arrangement, scheme participation, and configuration. Applicability should be verified against the latest MNRE guidance for each project — this is not a blanket exemption.

  • Projects already bid out where the last bid-submission date fell before the relevant notification remain exempt from List-II even if commissioned later.

C&I rooftop projects come in several configurations — net-metered, captive, group captive, open access, zero-export, gross-metered — and coverage differs across them. Since many industrial rooftop installations use net metering or open access, most grid-connected C&I buyers should plan around the December 31, 2026 transition date unless a documented exemption applies.

How does ALMM List-II affect solar project costs?

It creates a two-phase cost environment — and the window matters. As of mid-2026, India has approximately 31 GW of approved solar cell manufacturing capacity compared with roughly 190 GW of module manufacturing capacity — a six-fold mismatch between the cells the rules will require and the module lines that need them.

Some industry estimates indicate the cost impact of transitioning to List-II compliant cells could be around 3–5% of total project cost, translating to roughly ₹0.10–0.20 per kWh on tariffs for power-purchase structures — industry projections rather than official figures, with actual impact varying by project. MNRE has also begun requiring ALMM manufacturers to report monthly cell and module prices to the National Institute of Solar Energy to keep the transition orderly.

What the December window means in practice:

  1. Projects commissioned by December 31, 2026 may continue using existing module supply chains where permitted under the transition window and applicable procurement conditions — a window during which manufacturers are motivated to move existing inventory.

  2. Projects commissioning from January 1, 2027 should be budgeted on compliant-cell economics — and contracts signed now for 2027 commissioning should allocate the risk of schedule slippage across that deadline explicitly.

  3. Re-validate older quotes either way. Proposals prepared before mid-2026 may not reflect current module pricing or the correct compliance assumptions for your commissioning date.

What should CFOs and sourcing heads do about it?

Treat ALMM compliance as a vendor-qualification gate, not a technical footnote. Five questions to put to any solar developer or EPC before signing:

  1. What commissioning date is my project realistically on — before or after December 31, 2026? This now determines your compliance regime and your cost base.

  2. If commissioning slips past the deadline, who absorbs the difference? The contract should say so explicitly.

  3. For 2027-and-beyond projects: are the proposed modules on ALMM List-I with cells from List-II? Ask for specific model numbers and verify against MNRE's published lists.

  4. Is module supply contractually secured for my commissioning window? A quote means little if the manufacturer's allocation is oversubscribed.

  5. Is my project structured to qualify for any exemption, and is that documented? Bid dates and connection configuration should sit in your project file, not in verbal assurances.

Does the OPEX model protect buyers from ALMM risk?

Largely, yes — and this is becoming one of the strongest arguments for the OPEX/RESCO route in 2026. Under a CAPEX model, you own the asset, which means you also own the procurement risk: module price movements, compliance verification, supply delays, and deadline-slippage exposure sit on your side.

Under an OPEX/RESCO structure, the developer owns, finances, and operates the plant — you simply buy the power at a contracted per-unit tariff. Module sourcing, ALMM compliance, supply-chain management, and cost absorption are the developer's responsibility, contractually. Where the PPA fixes the tariff — as is typical in well-structured OPEX agreements — procurement and compliance risk sits with the developer, not with you.

That doesn't make the developer's competence irrelevant — it makes it more important. A developer without manufacturer relationships and secured supply can delay your commissioning past the window regardless of who owns the risk on paper.

What happens if a project doesn't comply?

For covered projects commissioned after their applicable deadline, non-compliance carries real consequences: such projects may be unable to obtain required approvals — including net-metering connection where ALMM compliance is mandated — and lose eligibility for subsidies. On the manufacturing side, module makers who fail to certify List-II cells risk delisting from List-I entirely, which would strand any project designed around their products. For a C&I buyer, the realistic failure mode isn't a fine; it's a commissioned plant that can't secure its approvals, sitting idle while the paperwork unwinds.

The bottom line for industrial buyers

The December 31, 2026 window is a genuine, dated opportunity: projects that commission within it are generally more likely to benefit from current supply-chain economics, while projects that slip into 2027 should plan for the compliant-cell cost structure and a tighter supply market. That makes the second half of 2026 the most time-sensitive stretch for C&I solar decisions in years — rooftop projects take months from agreement to commissioning, so the window is effectively closing now, not in December.

SustVest delivers rooftop solar across both OPEX and CAPEX models — as a CRISIL Top-10 Rooftop Solar Developer with 83+ projects across 13+ states. Book a free site assessment and find out whether your facility can still commission inside the December 2026 window.

Frequently Asked Questions

What is ALMM List-II in solar? ALMM List-II is MNRE's approved list of domestically manufactured solar PV cells. Solar modules used in notified project categories in India must contain cells from manufacturers on this list, with net-metering and open-access projects required to comply from January 1, 2027.

Has the ALMM List-II deadline been extended? Partially. ALMM List-II came into force on June 1, 2026, and MNRE has stated there is no blanket extension. However, under its July 18, 2026 order, net-metering and open-access projects may commission with exemption from List-II until December 31, 2026.

Does ALMM List-II apply to private industrial rooftop solar? If the project falls within MNRE's notified categories — such as net-metered or open-access projects — yes, with compliance applying to commissioning from January 1, 2027. Certain purely behind-the-meter captive configurations may fall outside the notified categories, but applicability must be verified against the latest MNRE guidance for each project.

How much does ALMM List-II increase solar project costs? Some industry estimates indicate a 3–5% increase in project costs, or roughly ₹0.10–0.20 per kWh on tariffs. These are industry projections rather than official figures, driven by the price premium and limited supply of domestically manufactured cells.

Can I avoid ALMM risk by choosing an OPEX solar model? Substantially, yes. Under OPEX/RESCO, the developer owns the asset and carries module procurement, compliance, and cost risk, while you pay only a contracted per-unit tariff for the power generated.

Will there be an ALMM List-III? MNRE has proposed implementing a List-III covering solar wafers from June 1, 2028, continuing the push toward a fully domestic solar supply chain.

Sources

  • MNRE O.M. No. 283/53/2026-GRID SOLAR (July 18, 2026): "ALMM List-II (for solar PV cells) — No blanket extension subject to limited window till 31.12.2026 for commissioning Net-Metering and Open Access RE power projects" — mnre.gov.in (official PDF: https://cdnbbsr.s3waas.gov.in/s3716e1b8c6cd17b771da77391355749f3/uploads/2026/07/202607181895863474.pdf)

  • MNRE notice: "No blanket extension of ALMM List-II beyond 01.06.2026, subject to protection of investments already made" (May 25, 2026) — mnre.gov.in

  • MNRE Office Memorandum No. 283/59/2024-GRID SOLAR (December 9, 2024)

  • MNRE draft amendment proposing List-III for solar wafers (September 2025)

  • Industry cost-impact estimates: Mercom India reporting (2025–26)