ALMM List-II Deadline: What C&I Solar EPCs Must Do by December

On 18 July 2026, MNRE handed the commercial and industrial solar market a hard date to plan around. The ALMM List-II deadline for solar PV cells, which had already lapsed for net-metering and open access projects on 31 May 2026, has been reopened as a limited window that closes on 31 December 2026. If you run an EPC building rooftop net-metering plants or open access captive projects, the calendar just became your most important engineering input. Every project you want commissioned under the old rules now has fewer than six months to reach the meter.

Direct answer. MNRE’s Office Memorandum No. 283/53/2026-GRID SOLAR, dated 18 July 2026, grants net-metering and open access renewable power projects a limited window to commission with exemption from ALMM List-II (solar PV cells) until 31 December 2026. Projects commissioned on or after 1 January 2027 must source modules from ALMM List-I and cells from ALMM List-II. There is no blanket extension beyond this date. The commissioning date, not the order date or the installation date, decides which rule applies to your project.

This post takes the deadline apart from the EPC operating angle. Not what ALMM is in theory, but what the 31 December cutoff does to a live project pipeline, which gate a plant is most likely to miss, and how to sequence engineering so a net-metering or open access project reaches synchronization before the window shuts. If your quarter depends on getting plants energized, this is your countdown plan.

What the 31 December 2026 ALMM List-II deadline actually changes

The change is narrow, and that is exactly why it is easy to misread. MNRE has not softened the ALMM List-II mandate. It has granted one category of projects a short runway to finish under the pre-existing sourcing rules. After 31 December 2026, net-metering and open access projects fall under the same List-I module plus List-II cell requirement that already governs government-backed and centrally-assisted solar.

The timeline below is the whole story in one view. Each row is a real MNRE position, and the direction of travel is one way — toward mandatory domestic cell sourcing.

Date	What it meant for net-metering / open access
09 Dec 2024	O.M. sets the original rule: projects commissioned on or after 1 June 2026 must use List-I modules and List-II cells
28 Jul 2025	MNRE reiterates the 1 June 2026 applicability date
25 May 2026	MNRE confirms no blanket extension of List-II beyond 1 June 2026
31 May 2026	Exemption window for net-metering / open access lapses
01 Jun 2026	ALMM List-II becomes mandatory for newly commissioned projects
18 Jul 2026	Limited window reopened — commission with cell exemption until 31 Dec 2026
01 Jan 2027	List-II cell sourcing becomes mandatory for these projects, no further extension signalled

The practical read is simple. A net-metering rooftop plant that reaches its commissioning certificate on 20 December 2026 can be built with modules assembled from imported or non-List-II cells. The same plant, commissioned on 5 January 2027, cannot. The bill of materials does not change. The calendar does. For a deeper look at how the underlying register shapes procurement, our guide on how the ALMM list affects your solar BOQ walks through the module-selection mechanics in detail.

Net-metering and open access: why these two categories got the window

MNRE drew the exemption around two specific project types, and the reasoning matters for anyone deciding whether their plant qualifies. Net-metering projects are behind-the-meter rooftop and small ground-mount systems where a consumer offsets their own DISCOM bill and exports surplus to the grid. Open access projects are larger captive or third-party plants that wheel power across the DISCOM network to an industrial or commercial offtaker under a power purchase agreement.

Both categories share a common problem the exemption is meant to solve. These are decentralized, developer-financed, and time-sensitive projects where the buyer is a factory owner or a facility, not a central procurement agency. Domestic cell manufacturing capacity under List-II is expanding but still concentrated, and forcing an abrupt switch would have stranded modules that developers had already bought and warehoused.

The Q1 2026 install surge tells you developers already understood the direction. According to Taiyang News, developers front-loaded 15.3 GW of installations in the first quarter of 2026, a 143% jump year on year, specifically to beat the tightening sourcing rules. The July window is a second, smaller runway for the projects that could not finish in that first sprint.

This relief does not extend to utility-scale plants tied to central auctions such as SECI tenders. A separate carve-out already exempts projects whose bids were submitted on or before 31 August 2025, regardless of commissioning date, so a central-auction plant should test that criterion rather than assume the July window applies. The exemption in this order is a decentralized-market instrument. If your project is a rooftop net-metering plant or an open access captive plant with a live DISCOM application, it is squarely in scope. If it is a SECI or state utility auction plant, check your PPA, letter of award, and bid date, because your compliance clock was set earlier and separately.

ALMM List-I vs List-II: the module and cell rule in plain terms

The single most common confusion on the ground is treating ALMM as one requirement. It is two layers, and the July window touches only the second one.

Layer	What it certifies	Status for net-metering / open access
ALMM List-I	Finished solar PV modules (models and makers)	Mandatory throughout — no exemption in the July order
ALMM List-II	Solar PV cells inside those modules	Exempt until 31 Dec 2026, then mandatory

Read the table carefully, because it protects you from an expensive mistake. The July 2026 window does not exempt you from List-I modules. Your modules must still be List-I approved regardless of when you commission. What the window suspends is the requirement that those approved modules be built from List-II approved cells. A module can be List-I certified today while the cells inside it come from a manufacturer not yet on List-II.

This distinction also separates ALMM from the Domestic Content Requirement. ALMM is an approval register; DCR is a domestic-manufacturing condition attached to specific subsidy schemes. A project can be ALMM compliant and still fall outside DCR, or the reverse. Our breakdown of DCR versus non-DCR solar panels explains where the two regimes overlap and where they do not, and the MNRE DCR compliance guide covers the documentation trail for subsidy-linked plants. Keep the three checks — List-I module, List-II cell, DCR — as separate line items in your engineering review. They fail independently.

The commissioning date is the only date that matters

Every conversation about this deadline eventually collides with one question: what counts as commissioned? The answer decides whether a project lands under the exemption or under full List-II compliance, and it is not the date you signed the supply contract or the day the last module went on the roof.

That gap between mechanical completion and formal commissioning is where projects die against a deadline. A plant can have 100% of its modules installed in November and still miss 31 December because the DISCOM meter was not fitted, the CEIG electrical inspection was pending, or the net-meter agreement had not been executed. MNRE has separately directed DISCOMs not to delay grid connectivity, wheeling, or energy banking solely because an exemption certificate is pending, but administrative reality varies by state.

For projects that are physically installed but not yet commissioned, MNRE has indicated case-by-case relief on documented, advanced-stage plants submitted through the DCR portal. Do not treat that as a safety net. According to Mercom India, the exemption process is documentation-heavy and time-bound, and DISCOM approval delays remain the single biggest threat to plants that installed early but commissioned late. The lesson for an EPC is blunt: plan backward from the commissioning certificate, not from module delivery.

If you are unfamiliar with the state-level commissioning steps, our DISCOM net-metering process master guide maps the approval sequence state by state, and the CEIG drawing approval process guide covers the electrical inspection gate that sits directly in front of synchronization.

The 5-Gate Commissioning Countdown

Here is the framework we use to sequence a net-metering or open access project against a fixed commissioning deadline. Call it the 5-Gate Commissioning Countdown. Each gate is a hard dependency for the next, and the whole chain must clear before 31 December 2026 for the exemption to hold. Missing any one gate resets your timeline, so the discipline is to work every gate in parallel wherever the rules allow.

Applied to a live project, the countdown works backward. If you want the certificate by mid-December to hold a buffer, gates 4 and 5 need October and November, which means detailed engineering must be complete by September, which means your sourcing decision and DISCOM sanction should already be closed today. A rep running this frame next week starts by listing every pipeline project by its current gate, then triaging which ones can realistically clear all five before the window shuts.

Commission before 31 December vs comply after: the decision

For every project in your pipeline, there are only two honest answers: race to commission under the exemption, or accept List-II compliance and plan the plant properly for a 2027 energization. The wrong move is to drift, assume you will make the deadline, and discover in December that gate 4 is stuck.

Dimension	Commission before 31 Dec 2026	Comply with List-II after
Cell sourcing	Exempt — imported or non-List-II cells allowed	List-II approved cells mandatory
Module price pressure	Lower near-term, uses existing inventory	Higher until domestic cell supply deepens
Schedule risk	High — five gates in under six months	Low — no artificial deadline
Supply certainty	Constrained by what is warehoused now	Constrained by List-II cell availability
Best for	Advanced-stage plants past gate 3	Projects still at gate 1 or 2

Verdict. For a net-metering or open access plant already past gate 3 with modules on hand, racing to commission before 31 December protects both cost and revenue and is worth the schedule stress. For a project still stuck at DISCOM sanction or without a locked module supply, chasing the deadline invites a stranded asset. Sort your pipeline by gate, not by hope, and commit each project to one lane.

The engineering mistakes that will cost you the exemption

The projects that miss this window rarely miss on modules. They miss on the engineering and approval steps that feed gates 4 and 5, and every one of these is preventable.

The first is a rejected CEIG or electrical drawing set. A single-line diagram that does not match the sanctioned scheme, missing protection coordination, or an incomplete earthing layout sends the inspection back and burns two to four weeks you cannot spare in Q4. The second is a structural design that stalls installation — an under-designed rooftop mount that fails load review, or a ground-mount foundation that ignores site geotechnical data. The third is a net-metering application filed against the wrong capacity or the wrong consumer category, which forces a resubmission at gate 1 and quietly wrecks the entire countdown.

The common thread is that these failures happen at the engineering desk, not at the module warehouse. An EPC that is short one designer, or whose in-house team is already saturated across projects, cannot flush a Q4 pipeline through gates 3 and 4 fast enough. That capacity gap is the real reason projects miss the deadline, and it is the one an EPC can fix without waiting on any DISCOM.

What the deadline means for your C&I project P&L

Strip away the policy language and the deadline reduces to a cost-and-revenue question for each plant. Two forces are in tension. Commissioning under the exemption lets you deploy modules already bought at pre-mandate prices and start the offtaker savings clock this year. Slipping past 31 December pushes you into List-II cell sourcing, where the near-term concern is supply depth rather than the register itself.

That supply concern is real. Analysis by Down To Earth flagged that the List-II rollout exposes a domestic cell shortage that could pressure standalone module makers and tighten availability in the near term. For a C&I developer, that translates into procurement uncertainty on any plant pushed into 2027 before domestic cell capacity deepens. The counterweight is that MNRE keeps expanding List-II with each revision — from 26 GW at the fourth revision in February 2026 to over 30 GW by the seventh revision on 30 April 2026, with HJT cells now included — so the constraint eases over time rather than tightening.

For the plant you can genuinely finish, the math favors commissioning now. For the plant you cannot, the disciplined move is to design it properly for List-II compliance rather than gamble on a case-by-case exemption. Either way, the deciding input is engineering throughput between now and December. If you want the official position in full, MNRE publishes its orders on the MNRE ALMM page, and SolarQuarter tracks the conditional-relief details as they evolve. When you have a plant on the line, talk to our team about a realistic gate-by-gate schedule.

How Heaven Designs helps

The bottleneck in beating this deadline is not policy interpretation. It is getting bankable, inspection-ready engineering out the door fast enough to clear gates 3, 4, and 5 before the window closes. That is exactly the bench Heaven Designs exists to be. When your in-house team is saturated across a Q4 pipeline, an external engineering desk turns a stalled project list into a commissioned one — without you hiring a designer you will not need in January.

• Solar Rooftop Detailed Engineering Design — full IFC pack for net-metering plants: GA, SLD, structural, and BOQ, built to your DISCOM format so gate 3 clears clean.
• Electrical CEIG Drawings — CEIG-approval-ready electrical drawings that pass inspection the first time, protecting gate 4 from a rework cycle.
• Solar Ground Mount Design — utility and open access captive layouts with civil and structural design grounded in real site data.
• Site Survey and Land Feasibility — early-stage feasibility so a project does not stall at gate 1 on a wrong-capacity application.
• Download a sample deliverable — see a redacted, submission-ready drawing set before you commit.

The engineering capacity to flush a pipeline before 31 December should be variable, not fixed to your current headcount. If you have plants to commission this year, send us your project list and we will help you sequence them against the deadline. You can also browse the full range of solar engineering services to see where the bench fits your workflow.

FAQ

What is the new ALMM List-II deadline for net-metering and open access projects?

Net-metering and open access renewable power projects may commission with exemption from ALMM List-II (solar PV cells) until 31 December 2026, per MNRE’s Office Memorandum No. 283/53/2026-GRID SOLAR dated 18 July 2026. Projects commissioned on or after 1 January 2027 must source cells from ALMM List-II and modules from ALMM List-I. MNRE has stated there is no blanket extension beyond this date. You can download the full MNRE Office Memorandum as a PDF for your records.

Does the exemption cover both solar modules and solar cells?

No. The exemption applies only to solar PV cells under ALMM List-II. Modules must still be sourced from ALMM List-I regardless of the commissioning date. A common and costly error is assuming the window covers modules — it does not. Only the requirement that approved modules use List-II approved cells is deferred until 31 December 2026.

What date does MNRE use to decide if a project qualifies?

The commissioning date. A project qualifies for the exemption if it is formally commissioned — synchronized to the grid and issued a commissioning certificate — on or before 31 December 2026. The order date, module delivery date, and installation date do not qualify a project on their own. Mechanical completion without a commissioning certificate does not meet the test.

My modules are installed but the plant is not commissioned yet. Do I lose the exemption?

Not automatically. MNRE has indicated case-by-case relief for advanced-stage projects that installed modules but await commissioning, subject to documentation submitted through the DCR portal. Treat this as a fallback, not a plan. DISCOM and CEIG delays remain the biggest risk, so push every project to a full commissioning certificate rather than relying on discretionary relief.

Does this deadline apply to SECI or utility-scale auction projects?

No. The July 2026 window is specific to net-metering and open access renewable power projects. A separate carve-out exempts projects whose bids were submitted on or before 31 August 2025, regardless of commissioning date, which is the relevant test for many central-auction plants. Utility-scale projects under SECI or state auctions should check that bid date, their letter of award, and their PPA rather than rely on the July window.

How much domestic cell capacity is on ALMM List-II?

MNRE has expanded ALMM List-II to over 30 GW of approved cell capacity by the seventh revision (30 April 2026), up from 26 GW at the fourth revision in February 2026, and the list now includes HJT cells. Capacity is growing with each revision, which is the stated reason for the transition window. The near-term concern for developers is availability depth rather than the register itself, so projects pushed into 2027 should confirm cell supply before committing to a schedule.

What is the fastest way to make sure a plant commissions before 31 December?

Work backward from the commissioning certificate using a gate-by-gate schedule, and clear detailed engineering early so the CEIG inspection and synchronization are not stuck behind drawing revisions in December. The most common preventable delay is a rejected drawing set at the electrical inspection stage. Front-loading bankable, inspection-ready engineering is the single highest-impact move for hitting the deadline.

Sources

The policy facts in this post are drawn from the MNRE order and primary industry reporting below. Where figures vary by revision, the article cites the specific revision date.

• MNRE Office Memorandum No. 283/53/2026-GRID SOLAR, dated 18 July 2026 (PDF) — the primary order, signed by Sanjay G. Karndhar, Scientist-E, MNRE
• MNRE — Current Notices (the 18 July 2026 notice: “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 — Approved List of Models and Manufacturers (ALMM)
• Business Standard — Govt extends exemption for net-metering, open access RE projects till December
• Taiyang News — India brings ALMM List-II for solar cells into force
• Mercom India — Solar cell capacity under ALMM List-II increases to 26 GW
• Mercom India — MNRE allows commissioning of projects awaiting ALMM-II exemption
• SolarQuarter — MNRE retains June 2026 ALMM List-II deadline with conditional relief
• PV-Tech — MNRE expands ALMM List-II, adds HJT cells for the first time
• Down To Earth — India’s solar rules spark concern over domestic cell shortage