Indian DISCOM Net Metering Compliance in 2026: What Installers Must Verify

An EPC that closed 40 rooftop net-metering projects in Gujarat last year cannot assume the same rules apply to a batch in Maharashtra this year, or even to Gujarat next year. Electricity is a state subject in India. Net metering runs on a national floor set by the Ministry of Power, then gets rewritten locally by each State Electricity Regulatory Commission (SERC) and interpreted, sometimes inconsistently, by each distribution company (DISCOM). In 2026 alone, the Ministry of New and Renewable Energy (MNRE) moved a key module-sourcing deadline three times, and a state regulator issued a fresh order overriding a DISCOM’s own billing practice. Installers who treat net-metering rules as fixed lose projects to rejections and billing disputes that a five-minute verification call would have caught.

Direct answer. India’s net-metering framework sets a national floor of 500 kW or sanctioned load, whichever is lower, under the Ministry of Power’s Electricity (Rights of Consumers) Amendment Rules, 2021, according to Mercom India. States set their own caps above that floor, DISCOMs enforce their own drawing formats and inspection processes, and MNRE has separately moved the ALMM List-II module-sourcing deadline for net-metering projects to 31 December 2026. Installers must verify current rules directly with the relevant DISCOM and SERC before every project, not rely on last year’s checklist.

This guide is for Suresh, the India-based EPC owner or business head running rooftop and C&I net-metering projects across two or more DISCOM territories. He does not need another explanation of what net metering is. He needs a clear read on what has actually moved in 2026, with sources he can check himself, and a repeatable process for catching the next rule change before it costs him a rejected project.

Why India’s net-metering rules cannot be treated as one national policy

Electricity distribution sits with the states under India’s constitutional structure. Each SERC writes its own net-metering regulations under the framework set by the Ministry of Power and the Central Electricity Regulatory Commission (CERC). The DISCOM then applies those regulations through its own application forms, drawing formats, and inspection processes.

The result is 54 functional DISCOMs, each running its own version of the same basic idea. Our state-by-state DISCOM net-metering process guide covers the submission mechanics in detail. This article focuses on what actually changed at the policy layer during 2026, and how to keep tracking it.

The national floor, set by the Ministry of Power’s Electricity (Rights of Consumers) Amendment Rules, 2021, permits net metering up to 500 kW or the consumer’s sanctioned load, whichever is lower, according to Mercom India, 2021. That figure is a floor, not a ceiling. States are free to raise it.

Maharashtra did exactly that. The Maharashtra Electricity Regulatory Commission (MERC) raised the state’s net-metering cap from under 1 MW to 5 MW, or the consumer’s contract demand or sanctioned load, whichever is lower, according to Mercom India. MERC also opened the door to group net metering, gross metering, and behind-the-meter connections as consumer options in the state. An EPC quoting a 2 MW C&I rooftop project in Maharashtra can pursue net metering there; the same project in a state that has not raised its cap above the national floor cannot.

That single example is the whole argument. A national floor plus 28 independent state regulators plus dozens of DISCOM implementation choices means “the net-metering rule” does not exist as one thing. It exists as a specific rule, in a specific state, checked on a specific date.

Who actually regulates net metering: MNRE, SERC, or the DISCOM

Installers often address every compliance question to the DISCOM, because the DISCOM is the party that approves or rejects the application. That is only partly right. Three different bodies control different layers of the rule, and knowing which one to approach saves weeks.

Layer	Who controls it	What it decides	How it usually changes
National floor	Ministry of Power	Minimum eligible capacity, baseline consumer rights	Central rule amendment, rare
State regulation	State Electricity Regulatory Commission (SERC)	State-specific capacity caps, tariff structure, net vs gross vs net-billing option	SERC order or amended regulation, occasional
Module and cell sourcing	MNRE (ALMM)	Which manufacturers are eligible for net-metering and open-access projects	Office Memorandum, has moved multiple times in 2026
Application, format, inspection	DISCOM	Drawing format, timelines, portal process, feasibility checks	Internal circular, frequent, least documented publicly

A capacity-cap dispute belongs with the SERC, because the DISCOM is only implementing a rule the SERC wrote. A sourcing-eligibility dispute belongs with MNRE, because ALMM is a central program. A rejected drawing belongs with the DISCOM’s own technical desk, because that format is theirs to set. Sending a format complaint to MNRE, or a sourcing-eligibility question to the DISCOM’s front counter, wastes a cycle each time. Route the question to the body that actually owns the answer.

This layered structure also explains why the MSEDCL case took over two years to resolve. The underlying rule change came from a SERC-level regulation amendment in 2023. MSEDCL, at the implementation layer, kept applying its old internal practice until a consumer escalated the conflict back up to MERC itself. The DISCOM had no independent authority to overrule the SERC’s regulation, but it also had no automatic mechanism to update its own practice the moment the regulation changed. That gap between a regulation change and DISCOM-level implementation is where most compliance risk for installers actually lives.

What actually changed in India’s net-metering compliance during 2026

Three verified developments moved the ground under installers this year. Each is real, dated, and sourced. None of them is a nationwide net-metering overhaul, and none of them should be assumed to apply outside the state or project category it covers.

MERC ordered MSEDCL to allow net metering alongside open access

On 1 January 2026, MERC directed the Maharashtra State Electricity Distribution Co. Ltd (MSEDCL) to permit net metering for rooftop solar consumers who are simultaneously availing open access, according to a Mondaq summary of the order. The dispute involved Hatsun Agro Product Limited, which sought net metering while also using open access power. MSEDCL had refused, citing an older requirement for gross metering during open access.

MERC found that the Distribution Open Access (Second Amendment) Regulations, 2023 had already deleted that requirement under Regulation 3.4, meaning consumers could legally combine open access and net metering. MERC ordered MSEDCL to reconcile the consumer’s overbilled amounts back to November 2023, with interest, in the next billing cycle.

The lesson for installers is not about Maharashtra specifically. It is that a DISCOM can keep applying an outdated internal rule for over two years after the underlying regulation changed, until a consumer or their EPC forces the issue through a regulatory complaint. If a DISCOM tells you a combination of net metering and open access is not permitted, ask for the specific regulation clause they are relying on and check its current version before accepting the answer.

MNRE moved the ALMM List-II sourcing deadline for net-metering projects three times

The Approved List of Models and Manufacturers (ALMM), maintained by MNRE, controls which module and cell manufacturers are eligible for use in government-linked, open-access, and net-metering projects. In 2026, MNRE’s applicability date for ALMM List-II (solar PV cells) on net-metering and open-access projects moved from a hard 1 June 2026 mandate to a reopened exemption window running to 31 December 2026, under Office Memorandum No. 283/53/2026-GRID SOLAR dated 18 July 2026.

We cover this deadline and its project-scheduling implications in full in our ALMM List-II commissioning deadline guide. The relevant point for this article: a project commissioned before 31 December 2026 can still use non-List-II cells under the current exemption. A project commissioned on or after 1 January 2027 cannot, unless MNRE issues a further extension. Track the commissioning date on every net-metering project against this calendar, not the installation date.

MNRE opened a one-time relief window for DISCOM-delayed commissioning

In mid-June 2026, MNRE clarified a separate, narrower relief mechanism. Rooftop solar projects that had 100 percent of required modules installed on site before 1 June 2026, but could not get commissioning certification from the DISCOM under net metering by that date for any valid reason, could apply for a one-time exemption from ALMM List-II, according to Saur Energy and Business Standard.

Applicants had to submit GIS-tagged photographs, invoices, daily installation reports, and a self-certification form through the NISE portal, within a one-month window from the clarification date. The DISCOM carried the responsibility to verify eligibility, certify the exemption, and keep a record of the installation-completion date and the reason for the commissioning delay.

MNRE explicitly framed this as transitional relief, not a general extension of the underlying deadline. That distinction matters for any EPC managing a backlog. A project that missed commissioning purely because the DISCOM sat on the file for weeks had a documented path to relief. A project that missed commissioning because the EPC’s own procurement was late did not automatically qualify.

The myth: “net metering rules only change once a year, at budget time”

Many EPCs plan their compliance review around the union budget or the start of a financial year, expecting net-metering rules to move once, then hold steady. The 2026 record contradicts that assumption. MNRE issued at least three separate communications affecting net-metering-linked ALMM sourcing between December 2024 and July 2026. MERC issued a binding order affecting open-access-plus-net-metering billing in the first week of January.

Neither of those changes arrived on a budget cycle. They arrived when a dispute reached a regulator, or when an earlier deadline proved unworkable and had to be revised. The realistic pattern is that DISCOM and MNRE compliance rules change on their own schedule, driven by disputes, industry pressure, and implementation problems, not a fixed annual calendar.

The tradeoff for EPCs is real. Building a formal quarterly compliance review costs staff time that could go toward sales or delivery. Skipping that review costs rejected applications, stalled commissioning, and in MSEDCL’s case, a regulator-ordered billing reconciliation with interest. For a business running more than a handful of net-metering projects a year, the quarterly review is the cheaper option.

Net metering versus gross metering: there is no universal winner

Where a state’s regulations permit both, choosing between net metering and gross metering is a real tradeoff, not a default decision. Net metering credits the consumer at the retail tariff for exported units, offset against imports, which typically produces better economics for a consumer with high daytime load matching their solar generation. Gross metering pays the consumer a separate feed-in tariff for every unit exported, regardless of how much they import, which can suit a consumer with a small connected load and a large, unshaded roof relative to their consumption.

Group net metering and behind-the-meter connections, where available, add further options for portfolio owners who want to allocate credits across multiple accounts under one entity. Maharashtra’s MERC opened all three of these paths, net metering, gross metering, and behind-the-meter, as consumer choices alongside the state’s 5 MW cap increase, according to Mercom India’s reporting on the order.

No single option is correct for every consumer. An EPC that defaults every quote to net metering without checking the consumer’s load profile against the available billing structures is leaving money on the table for some customers, and in states where net metering is capacity-constrained, may be proposing a structure the DISCOM will not approve at all. Model both options where the state permits a choice, and let the consumer’s actual load profile decide.

A practical DISCOM compliance verification checklist

Run this checklist before quoting, before design, and again before commissioning submission, on every project. It is built to catch a rule change between the last project you closed and the one you are about to submit.

1. Confirm the current net-metering capacity cap for the specific DISCOM and consumer category. Do not rely on last year’s figure. Call the DISCOM’s net-metering or renewable energy cell, or check the current SERC net-metering regulations directly.
2. Confirm whether the project is eligible for net metering, gross metering, or a net-billing hybrid in that state. Some states offer more than one option above certain capacities; the consumer’s economics differ materially between them.
3. Check the DISCOM’s current drawing and application format. Formats change more often than headline policy. Our DISCOM rejection reasons guide documents the most common format-driven rejections.
4. Confirm the module and cell sourcing rule that applies on the expected commissioning date, not the design date. With ALMM List-II sourcing tied to a moving commissioning-date cutoff in 2026, the rule that applied when you signed the contract may not be the rule that applies when the plant reaches its meter.
5. If the project involves both open access and net metering, get the DISCOM’s position on that combination in writing, with a regulation clause reference. The MSEDCL case shows a DISCOM can hold an outdated position for years without being challenged.
6. Ask whether the DISCOM has any active, unresolved backlog affecting commissioning timelines, and whether any transitional relief mechanism, like the June 2026 NISE self-certification window, is currently open for delayed projects.
7. Log the verification date and source (DISCOM circular number, SERC order number, or officer name and designation) for every project file. This record is what protects the EPC if a rule changes again after submission.
8. Re-run this checklist at project kickoff and again immediately before commissioning submission, not only once at the start of the relationship.

What most EPCs get wrong about tracking compliance

The most common mistake is assigning compliance tracking to whichever engineer last worked on a project in that state, informally, without a written source. That works until the engineer moves teams or the DISCOM changes its officer. The information leaves with the person.

The fix is boring but effective: a shared, dated compliance log per DISCOM, updated by whoever last confirmed a rule, with the source cited. It does not need software. A shared spreadsheet with columns for DISCOM, rule, current value, source, and verification date covers most of the value. What it prevents is re-learning the same lesson MSEDCL’s counterpart learned the hard way, at a regulator’s direction, with interest attached.

A second common mistake is confusing an MNRE-level module-sourcing rule, like ALMM List-II, with a DISCOM-level net-metering capacity or format rule. They are governed by different bodies, on different timelines, and a change in one does not imply a change in the other. Track them separately.

Where engineering documentation fits into compliance, not just design

A DISCOM rejection for an outdated drawing format or an inconsistent single-line diagram (SLD) is a compliance failure, not just a design error. The electrical SLD and CEIG drawing package that accompanies a net-metering application has to match the DISCOM’s current format exactly, because most DISCOM reviewers reject on format mismatch before they evaluate the underlying design.

For EPCs managing net-metering submissions across multiple DISCOM territories at volume, keeping every state’s current format, application checklist, and structural documentation current in-house is a real operating cost. A rooftop detailed engineering design partner that already tracks DISCOM-specific formats across states removes that burden from the EPC’s own team, and reduces the chance that a stale template causes a rejection. You can review a sample DISCOM-ready drawing package to see what a current-format submission looks like before you commit engineering hours to your own version.

None of this replaces direct verification with the DISCOM. It reduces how often that verification catches your team by surprise mid-project.

Practical impact for EPC operations, project by project

A capacity-cap change decides whether a project can even pursue net metering, or must default to gross metering or a captive open-access structure instead, which changes the consumer’s return-on-investment pitch entirely. An ALMM sourcing-date change decides which module supplier a procurement team can use for a given commissioning window, months before the project reaches site. A format change decides whether a completed application gets accepted on first submission or bounces back for a redraw.

Each of these has a different owner inside a typical EPC: sales owns the capacity-cap conversation with the customer, procurement owns the ALMM sourcing decision, and the design or documentation team owns the format compliance. A compliance tracking process that only lives with one department misses the changes that affect the other two.

Consider a 2 MW C&I rooftop project sold in Maharashtra during the first half of 2026. The sales team quoted net metering based on the state’s 5 MW cap. Procurement selected modules based on the ALMM List-II exemption then in force. Midway through construction, MNRE reissued its position on List-II applicability, and the commissioning date slipped past the original 31 May 2026 cutoff before the 18 July 2026 reopening arrived. Without a written log of which rule applied on which date, the EPC would have had no clean way to show a lender, or the DISCOM, that its sourcing decision was compliant at the time it was made. A dated compliance log turns that into a two-minute lookup instead of a reconstruction exercise under pressure.

The same discipline applies to billing disputes. If MSEDCL had kept a dated internal log tied to the 2023 regulation change, the Hatsun Agro Product dispute likely never reaches MERC. The DISCOM’s own failure to update its practice, not any ambiguity in the rule itself, created the two-year billing error. EPCs are not immune to the same failure mode internally. A design team using a net-metering capacity assumption from a project closed 18 months ago, without re-checking it, is repeating MSEDCL’s mistake at a smaller scale.

How to build a lightweight DISCOM compliance tracker without new software

Most EPCs do not need a dedicated compliance platform to fix this. A shared spreadsheet, reviewed monthly by whoever owns DISCOM relationships, covers the core need. The minimum useful structure has one row per DISCOM and separate columns for: current net-metering capacity cap, net vs gross vs net-billing options available, current application format version, current ALMM sourcing rule as it applies to that DISCOM’s typical commissioning timeline, source document or officer contacted, and verification date.

The discipline that matters more than the tool is the update cadence. A tracker that is accurate on the day it is built but never revisited is worse than no tracker, because it creates false confidence. Assign one person per DISCOM relationship the explicit responsibility of re-verifying their row at least quarterly, and log the date every time, even when nothing changed. An empty “last verified” column is the single clearest sign of compliance risk in a growing EPC’s operations.

Conclusion

India’s net-metering compliance landscape moved on three separate fronts in 2026: a state regulator forced a DISCOM to correct an outdated billing practice, MNRE moved a module-sourcing deadline twice, and MNRE opened a narrow relief window for DISCOM-caused delays. None of these were nationwide, none were permanent, and none should be assumed to still hold true by the time you read this without a fresh check.

• Verify the current net-metering cap and format for your specific DISCOM before every quote, using the DISCOM’s own renewable energy cell or the SERC’s published regulations.
• Track ALMM List-II sourcing rules against your expected commissioning date, not your design date, and revisit the deadline before every procurement decision.
• Keep a dated, sourced compliance log per DISCOM so the information survives staff turnover and holds up if a rule is later disputed.

If you want a second set of eyes on your current DISCOM documentation, or a sample of a format-compliant submission package, contact our engineering team for a project-specific review.

FAQ

Does India have one national net-metering policy?

No. The Ministry of Power sets a national floor under the Electricity (Rights of Consumers) Amendment Rules, 2021, permitting net metering up to 500 kW or sanctioned load, whichever is lower. Each state’s SERC can set a higher cap, and each DISCOM applies its own application process and format on top of that.

What is the current net-metering capacity cap in India?

The national floor is 500 kW or sanctioned load, whichever is lower. Individual states can raise this. Maharashtra, for example, raised its cap to 5 MW or contract demand, whichever is lower, according to Mercom India. Always confirm the specific figure with the relevant SERC or DISCOM before quoting a project.

What is the ALMM List-II deadline for net-metering projects in 2026?

MNRE’s Office Memorandum No. 283/53/2026-GRID SOLAR, dated 18 July 2026, extended the exemption window for net-metering and open-access projects to 31 December 2026. Projects commissioned on or after 1 January 2027 must source modules from ALMM List-I and cells from ALMM List-II, unless MNRE issues a further extension.

Can a project combine open access and net metering?

It depends on the state’s current regulations. In Maharashtra, MERC confirmed on 1 January 2026 that consumers can combine open access and net metering under the Distribution Open Access (Second Amendment) Regulations, 2023, after MSEDCL had incorrectly denied this combination. Confirm the equivalent regulation in your project’s state before assuming the same applies.

What should an EPC do if a DISCOM cites an outdated rule?

Ask the DISCOM’s officer for the specific regulation clause or circular number they are relying on, then check its current, in-force version against the SERC’s published regulations. If the DISCOM’s position conflicts with a currently valid regulation, that is grounds for a formal complaint to the SERC, as happened in the MSEDCL open-access case.

How often should an EPC re-check DISCOM net-metering rules?

At minimum, quarterly for any DISCOM where you run active volume, and again on every individual project at both the quoting stage and immediately before commissioning submission. Rules affecting module sourcing, in particular, are tied to commissioning dates that can shift during a project’s build cycle.

Where can I find the DISCOM-specific application and drawing format?

Most major DISCOMs publish their net-metering application forms and technical formats on their own websites or consumer portals. Our state-by-state DISCOM net-metering process guide lists the process and documentation baseline for 12 major DISCOMs as a starting reference, but always pull the current version directly from the DISCOM before submission.

Does MNRE’s ALMM relief window mean the ALMM List-II deadline is cancelled?

No. MNRE explicitly described the June 2026 relief mechanism as transitional support for projects delayed by DISCOM processing, not a cancellation or blanket extension of the underlying ALMM List-II applicability date. The separately extended 31 December 2026 window is the operative deadline for net-metering and open-access commissioning as of this writing.