The December 2026 ALMM Deadline: A C&I Solar Action Guide
By Hardik BhatiaPublishedDecember 31, 2026 is now a critical date for many businesses planning net-metered or open-access solar projects in India — but it is not a universal ALMM deadline for every rooftop project. What ends on that date is a temporary exemption from the ALMM List-II solar-cell requirement, available to certain project categories. For projects covered by it, missing the date means losing that exemption and moving into the applicable compliance regime — and because eligibility is tied to commissioning (not ordering) and rooftop projects take months to build, the practical window to act is already narrowing.
Under MNRE's order of July 18, 2026, eligible net-metering and open-access renewable energy projects can commission without complying with ALMM List-II (the domestic solar-cell requirement) until December 31, 2026. Projects commissioned on or before that date may use modules whose cells are not on ALMM List-II, provided they meet the applicable ALMM List-I requirements; from January 1, 2027, the exemption ends and List-II applies where it is required. A further MNRE clarification dated August 4, 2026 set out how this works across different project categories — so eligibility depends on your project type, bid dates, and commissioning timeline, and should be confirmed rather than assumed.
Here's exactly what the deadline means and the steps to take before it closes.
What is the December 31, 2026 ALMM deadline?
It's the last date on which eligible net-metering and open-access projects can be commissioned while still using solar cells that aren't listed under ALMM List-II. MNRE's Office Memorandum (July 18, 2026) opened this transition window for these two project categories, superseding earlier May–June 2026 notifications. It replaced the position under which these projects, commissioning from June 1, 2026, would have needed both ALMM List-I modules and cells from manufacturers listed under ALMM List-II.
An important distinction: this is an exemption from the List-II cell requirement — it is not a blanket exemption from ALMM. ALMM List-I (the approved list of solar modules) continues to apply where it is required; the December window defers only the List-II cell-sourcing obligation for these two categories. ALMM itself is not "starting" or "ending" on December 31 — what ends is the temporary List-II exemption.
Two things about the date matter for planning:
It's a firm cut-off, not a soft target. MNRE has been explicit that there is no blanket extension of ALMM List-II — full compliance continues everywhere it already applies, and the ministry framed this as a limited window. Planning as if a further extension will arrive is a risk, not a strategy.
It's tied to the project's commissioning date, not to ordering equipment or completing installation. A project that is merely ordered, or installed but not yet commissioned, by the deadline does not qualify. This makes timeline planning critical.
For the underlying policy — what ALMM List-I and List-II actually are — see our explainer on what ALMM List-II means for C&I buyers. This guide focuses on the deadline and what to do about it.
Does the December 2026 deadline apply to my project?
It applies to eligible net-metering and open-access renewable energy projects — but a further MNRE clarification dated August 4, 2026 set out distinct treatment for different project categories, so this is not a single deadline covering every rooftop. The August 4 memorandum clarified how List-II applicability works across project types based on project category, bid-submission dates, and commissioning timelines.
The categories are treated differently, so identify which one your project falls in:
Net-metering projects — covered by the December 31, 2026 window, subject to the applicable MNRE provisions.
Open-access renewable projects — covered by the December 31, 2026 window, subject to the applicable MNRE provisions.
Captive and behind-the-meter (BTM) projects — treated separately under the August 4 clarification, with different treatment reported for private versus government/PSE consumers. Do not assume a captive or BTM project is covered on the same basis as an open-access project; confirm its specific treatment.
Government-building rooftop projects — a separate category, with treatment reportedly determined by bid-submission dates (several bid-date cut-offs apply), and separate handling for projects not awarded through competitive bidding. A government rooftop project should not be assumed to fall under the December 31 C&I window without checking.
Other categories, including competitively bid and utility-scale projects — have separate treatment under MNRE's rules, including bid-date-based provisions for certain projects. (This window does not mean these categories have no treatment — it means their treatment is defined elsewhere.)
Subsidy (DCR) claimants — if you're claiming central subsidy, Domestic Content Requirement rules still apply and are unchanged; the List-II exemption does not remove the DCR obligation.
Because the interaction of category, bid date, and commissioning date is genuinely intricate after the August clarification, any project near a boundary should have its specific eligibility confirmed against the current MNRE memoranda rather than assumed.
Why does commissioning before December 31, 2026 matter financially?
Commissioning within the window preserves access to a broader pool of cell and module configurations that may otherwise become restricted once List-II compliance applies — but it does not guarantee lower prices. The exemption was introduced to facilitate a smoother transition to List-II — protecting existing module-manufacturer inventories and investments while domestic solar-cell manufacturing capacity continues to expand. That base is still growing: MNRE's latest List-II revision, dated August 21, 2026 (the ninth), added about 3.71 GW of solar-cell capacity, taking total enlisted List-II capacity to about 35.47 GW. The window gives the supply chain time to catch up as this capacity scales.
For a C&I buyer, the practical implications are:
Module choice and availability — commissioning inside the window keeps a wider set of modules eligible; after it, sourcing narrows to cells listed under List-II where List-II applies.
Cost is not one-directional. A broader supply base can support competitive pricing, and a tighter compliant-cell market can carry a premium — but the rush to commission before the deadline is itself tightening supply in some segments. Industry reporting in 2026 has noted developers accelerating commissioning, which can extend lead times and push up costs for certain module types. So buyers should not assume that waiting until late 2026 will produce lower prices, nor that missing the window automatically means much higher ones — the effect varies by project, segment, and timing.
Timeline certainty — as the deadline approaches, project execution and commissioning timelines could come under greater pressure; leaving it late risks missing the window through scheduling rather than equipment.
This is why the ownership model interacts with the deadline. Under a CAPEX project, you carry the procurement and timeline risk of hitting the date. Under an OPEX/RESCO structure, the developer typically manages procurement and commissioning — but the contract should clearly specify who bears the risk if the project misses the deadline. That allocation is worth settling explicitly when choosing how to fund a project right now.
What should C&I buyers do before the deadline?
Treat the timeline as the binding constraint and work backwards from December 31, 2026. Because commissioning — not ordering — is what counts, and because approvals, metering, and grid connection all take time, the runway is shorter than it looks. Practical steps:
Confirm your project's eligibility now. Establish, against the current MNRE memoranda, whether your project category and dates place it inside the window — especially if it's a bid-awarded or subsidy-linked project.
Build a realistic commissioning schedule backwards from the deadline. Include design, statutory and utility approvals, structural work, supply, installation, inspection, metering/open-access approvals where applicable, and energisation — not just equipment lead time.
Lock module supply early. If you intend to use the window, secure eligible module supply before the year-end rush tightens availability.
Decide OPEX vs CAPEX with the deadline in mind. If timeline risk concerns you, a developer who carries commissioning risk contractually may be the safer route (see OPEX vs CAPEX).
Have a 2027 plan too. If your project realistically can't commission by December 31, 2026, plan from the start for List-II-compliant sourcing rather than assuming another extension.
A developer who can map this backwards from the deadline for your specific site — and commit to a commissioning date — is doing the planning that actually protects your position.
What happens to projects commissioned after December 31, 2026?
For net-metering and open-access projects that are subject to ALMM, the December 31, 2026 exemption ends after that date, and the applicable ALMM List-I module and List-II cell requirements take effect from January 1, 2027, where those requirements apply. Such projects lose the transition-window flexibility: cells not listed under List-II are no longer permitted where List-II applies, and sourcing must be from the compliant domestic base. (Some categories clarified in the August 4 memorandum — such as certain behind-the-meter captive projects — have their own treatment, so "everything must comply from January 1" is too broad; check your category.) Missing the window isn't a barrier to going solar — it's the standard regime the market is moving toward — but projects that miss it should be budgeted and scheduled on compliant-cell terms from the outset, not on pre-deadline assumptions. Whether MNRE issues any further order closer to the date is not something a project plan should rely on; the prudent course is to plan to the rules as they stand.
The bottom line for C&I buyers
The December 31, 2026 date is a genuine, dated fork in the road for eligible net-metering and open-access solar projects — though not, as the August clarification makes clear, a single universal deadline for every rooftop. For covered projects, commissioning inside the window keeps today's wider module choice and supply flexibility; commissioning after moves them to the full List-II compliant-cell regime where it applies. Because eligibility is tied to commissioning and rooftop projects take months to build, the decision window is effectively open now and closing steadily. The buyers who benefit are those who confirm which category their project falls in, schedule backwards from the date, and move — not those who wait for a clarity the rules say isn't coming.
SustVest delivers rooftop solar under OPEX and CAPEX models and can assess which ALMM category your project falls in and whether it can realistically commission inside the December 2026 window — as a rooftop solar developer recognised by CRISIL Bridge to India among India's Top 10 rooftop solar project developers (Solar Rooftop Map, December 2025), with 83+ projects delivered across 13+ states. Book a free site assessment to get a deadline-aware plan for your facility.
Frequently Asked Questions
What is the December 31, 2026 ALMM deadline? It is the last date on which eligible net-metering and open-access renewable energy projects covered by the MNRE window can be commissioned while using solar cells not listed under ALMM List-II. Under MNRE's July 18, 2026 order, projects commissioned by that date may use such cells provided they meet applicable List-I requirements; from January 1, 2027, the List-II exemption ends where List-II applies.
Does the ALMM December 2026 deadline apply to all solar projects? No. The December 31, 2026 window announced on July 18 applies specifically to eligible net-metering and open-access renewable energy projects. Other categories, including competitively bid and utility-scale projects, have separate treatment under MNRE's rules, including bid-date-based provisions for certain projects, and behind-the-meter captive projects are treated separately under MNRE's August 4, 2026 clarification. Specific eligibility should be checked.
Does the project need to be installed or commissioned by December 31, 2026? The relevant date is commissioning, not merely ordering equipment or completing installation. A project that is only ordered or installed but not commissioned by the deadline does not qualify for the exemption, which is why timeline planning is critical.
What happens to net-metering and open-access projects after December 31, 2026? For projects that are subject to ALMM, from January 1, 2027 the applicable ALMM List-I module and List-II cell requirements take effect where those requirements apply. Cells not listed under List-II are no longer permitted where List-II applies, so post-deadline projects should be planned and budgeted on compliant-cell terms. Some categories clarified in August 2026 have separate treatment, so confirm your project's specific position.
Does the deadline affect projects claiming government subsidy? Projects claiming central subsidy remain subject to Domestic Content Requirement (DCR) rules, which are unchanged. The List-II exemption does not remove the DCR obligation for subsidy claimants, so both should be checked for a subsidy-linked project.
Will the ALMM deadline be extended again? MNRE has described this as a limited window and has not announced a further extension, reiterating that there is no blanket extension of ALMM List-II. A project plan should not assume a further extension; the prudent approach is to plan to the current rules and commission within the window if you intend to use it.
Sources
Primary (MNRE / government)
MNRE — Office Memorandum No. 283/53/2026-GRID SOLAR (July 18, 2026): limited ALMM List-II exemption window to December 31, 2026 for net-metering and open-access projects — mnre.gov.in
MNRE — Office Memorandum dated August 4, 2026: clarification of List-II applicability by project category, bid-submission date, and commissioning timeline; DCR provisions unchanged
MNRE ALMM List-II — 9th revision dated August 21, 2026: added ~3.71 GW, taking total enlisted List-II capacity to ~35.47 GW. The register updates frequently; treat as point-in-time.
PIB — July 18, 2026 announcement confirming the OM number and the limited relief window
Industry reporting 5. Mercom India — August 4 clarification coverage; deadline-driven supply/commissioning pressure (2026) 6. PV-Tech, TaiyangNews, Saur Energy — July–August 2026 reporting on the exemption and category treatment