MNRE Issues Detailed Clarification on ALMM List-II Applicability Across Solar Project Categories
The Ministry of New and Renewable Energy has issued a comprehensive clarification on the applicability of ALMM List-II for solar PV cells across competitive bidding, rooftop solar, net metering, open access, behind-the-meter and Domestic Content Requirement (DCR)-based solar projects.
August 05, 2026. By Mrinmoy Dey
The clarification seeks to remove ambiguity regarding the implementation of ALMM List-II across different categories of solar projects, including competitively bid projects, rooftop solar installations, net metering, behind-the-meter systems, government projects and projects under the Domestic Content Requirement (DCR) framework.
The ministry clarified that solar projects awarded through competitive bidding will remain exempt from the mandatory use of ALMM List-II-listed solar PV cells if the last date for bid submission was on or before August 31, 2025, provided the bids were live as of July 28, 2025. However, it noted that where tender documents for bids submitted between December 9, 2024 and July 28, 2025 had explicitly mandated the use of ALMM List-II-listed cells, those tender conditions would continue to apply.
According to the ministry, the amendment issued on July 28, 2025 only shifted the general cut-off date for ALMM List-II applicability from December 9, 2024 to August 31, 2025 and does not override conditions already specified in tender documents.
For net metering and open access projects, MNRE stated that all projects commissioned on or before December 31, 2026 will be exempt from ALMM List-II requirements for solar PV cells. The ministry clarified that this exemption applies irrespective of whether the projects were initiated before or after July 18, 2026, and developers will not be required to submit any application through the NISE Solar DCR Portal to avail the exemption. However, compliance with ALMM List-I for solar PV modules will continue wherever applicable.
The clarification also extends relief to residential consumers opting for the 'Give It Up' subsidy option under the PM Surya Ghar: Muft Bijli Yojana. Such projects will remain exempt from ALMM List-II requirements until March 31, 2027, provided applications are submitted exclusively through the PM Surya Ghar National Portal.
The ministry reiterated that ALMM List-I requirements for solar modules would continue to apply. It further clarified that the term 'Net Metering' includes Gross Metering, Net Billing, Net Feed-In, Virtual Net Metering and Group Net Metering, while specifically excluding Behind-the-Meter (BTM) projects.
With regard to rooftop solar projects on government buildings, MNRE has categorised exemptions based on bidding timelines. Projects with bid submission deadlines on or before December 9, 2024 will remain exempt from ALMM List-II, while projects with bid submission dates between December 9, 2024 and July 28, 2025 will continue to follow the provisions specified in their respective tender documents. Projects with bid submission dates between July 28, 2025 and August 31, 2025 will also be exempt from ALMM List-II, whereas projects with bid submission deadlines after August 31, 2025 will be required to comply with ALMM List-II requirements.
For government rooftop projects that are not awarded through competitive bidding, the ministry clarified that projects commissioned on or before December 31, 2026 will remain exempt from ALMM List-II, while those commissioned after this date must use ALMM List-II-listed solar PV cells.
The Office Memorandum also provides clarity on Behind-the-Meter solar projects. It states that both ALMM List-I and ALMM List-II will not apply to BTM solar power plants established for captive consumption by private consumers or groups of consumers, excluding government entities and public sector enterprises (PSEs).
However, for government entities and PSEs, projects commissioned on or before December 31, 2026 will be required to use ALMM-listed solar PV modules but will remain exempt from ALMM-listed solar PV cells. Projects commissioned after December 31, 2026 will be required to use both ALMM-listed solar PV modules and ALMM-listed solar PV cells.
MNRE also clarified that the latest ALMM-related Office Memoranda do not alter or dilute the Domestic Content Requirement (DCR) provisions applicable under various government schemes. The ministry stated that DCR obligations will continue to be governed by the respective scheme guidelines and subsequent amendments, and the ALMM clarifications should not be interpreted as providing any relaxation in the mandatory use of domestically manufactured solar PV modules or solar PV cells under DCR-based programmes.
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