MNRE Proposes Amendment to ALMM Order to Introduce Wafer-level Compliance
The proposed framework seeks to extend the ALMM regime across the solar manufacturing value chain by mandating the use of ALMM-enlisted wafers, in addition to modules and cells, for projects falling within the scope of the ALMM Order.
April 17, 2026. By News Bureau
The ALMM mechanism was originally introduced by MNRE to protect domestic manufacturers from dumping of foreign solar products and currently applies to solar modules under ALMM List-I and solar cells under ALMM List-II. The proposed amendment extends this framework to include ingots and wafers, a segment that remains heavily import-dependent. The issuance of ALMM List-III is contingent upon fulfilment of a market-readiness threshold: at least three independently operating wafer manufacturing units, not under common ownership or control, must be enlisted with a minimum aggregate manufacturing capacity of 15 (fifteen) gigawatts per annum. This pre-condition is designed to ensure adequate domestic supply exists before compliance becomes enforceable.
A distinguishing feature of the proposed amendment is its integrated manufacturing requirement for enlistment. For inclusion in ALMM List-III, wafer manufacturers are required to have ingot manufacturing capacity equivalent to the wafer manufacturing capacity proposed for enlistment. Accordingly, the enlisted wafer capacity will reflect both ingot and wafer manufacturing capabilities. This requirement promotes upstream integration within the solar value chain. From the Effective Date, projects covered under the ALMM framework will be required to ensure complete value chain compliance. Solar PV modules must be sourced from ALMM List-I, such modules must use solar PV cells from ALMM List-II, and such cells must in turn use wafers from ALMM List-III. This cascading compliance requirement closes a gap where domestic module and cell requirements could be satisfied through the use of imported wafers. The eligibility of modules under ALMM List-I will, from the Effective Date onwards, be linked to the wafer-level sourcing of the cells used in their manufacture non-compliance with this traceability requirement may result in delisting from ALMM List-I.
Projects where the last date of bid submission falls on or before 7 (seven) days from the issuance of the initial ALMM List-III for wafers (“Cut-Off Date”) will continue to be required to use ALMM-listed modules and cells but will be exempt from using ALMM-listed wafers, irrespective of their commissioning date. This exemption also extends to projects where bids or PPAs were executed prior to the Cut-Off Date. Conversely, projects where the last date of bid submission falls after the Cut-Off Date must incorporate conditions mandating the use of ALMM-listed modules, cells and wafers from List-I, List-II and List-III, respectively.
To accommodate the transitional requirements of exempt project categories, MNRE has proposed the creation of parallel ALMM sub-lists. These sub-categories are intended to provide continued regulatory clarity for projects that remain subject to module or cell-level requirements under the existing framework but are exempt from wafer-level compliance. The Memorandum further provides for differentiated applicability based on project category and commissioning timeline. Net-metering and open access projects commissioned before the Effective Date are exempt from the wafer requirement, though compliance with ALMM List-I and ALMM List-II continues. Projects commissioned on or after the Effective Date will be required to comply with all three ALMM lists. Government-owned captive projects are subject to a phased compliance approach: those commissioned before June 1, 2026 need only use ALMM-listed modules; those commissioned between June 1, 2026 and the Effective Date must use ALMM-listed modules and cells; and those commissioned on or after the Effective Date must comply with ALMM requirements in their entirety (including wafers).
An important carve-out has been introduced for thin-film technology manufactures. Thin-film solar PV modules manufactured in integrated facilities and enlisted under ALMM List-I are deemed to be compliant with the requirements of using ALMM-listed cells and wafers. This provision addresses the structural differences in the manufacturing process for thin-film modules, which do not use conventional crystalline silicon wafers, and is expected to benefit manufacturers that already operate under the ALMM framework.
In a clarification, the Memorandum expressly states that there will be no relaxation in domestic content requirement provisions under existing MNRE schemes such as PM-KUSUM (Components B & C), PM Surya Ghar: Muft Bijli Yojana and CPSU Scheme Phase-II. Detailed procedural guidelines for enlistment under ALMM List-III for wafers are proposed to be issued.
The proposed introduction of ALMM List-III marks a significant extension of the ALMM framework to the upstream wafer segment, introducing a more integrated approach to domestic solar manufacturing. By linking eligibility across the value chain and prescribing phased applicability, the proposal seeks to strengthen supply chain traceability and domestic manufacturing capabilities.
- Vishnu P Sudarsan, Partner; Sugandha Somani Gopal, Partner; Priyanka Barik, Senior Associate and Vihaan Pathak, Associate, JSA Advocates & Solicitors
please contact: contact@energetica-india.net.
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