Regulatory Update: Energy, Infrastructure, Mining & Environment Regulatory December 2025

1. Draft Guidelines on Mining Plan for Underground Coal and Lignite Gasification Blocks, 2025.¹ 

On 27^th October 2025, the Ministry of Coal initiated consultation with stakeholders on Mining Plan Guidelines for Coal and Lignite 2025 (“Guidelines”), inviting comments until 26^th November 2025. These Guidelines aim to optimise coal and lignite extraction using sustainable technology under the Mines and Minerals (Development and Regulation) Act, 1957 (“MMDR Act”). 

• Mining Plan Requirement: All coal or lignite gasification mines must prepare a mining plan founded on a pilot study assessing its feasibility, safety and environmental impact. The mining plan requires approval by the Coal Controller Organization (“CCO”). 
• Mine Closure Plan Requirements: The guidelines also mandate a detailed mine closure plan to ensure scientific site rehabilitation, minimizing environmental degradation, and restoring land to a usable or near-original site. The plan should also include –
• A progressive closure plan, updated every five years, covering ongoing land restoration; 
• A final closure plan for end-of-mine activities; and 
• Establishment of an escrow account with the CCO before commencing operations. 

These requirements align with the sustainability obligations under the MMDR Act and promote responsible resource extraction practices. 

2. Ministry of Coal Proposes Reforms to Land Acquisition Notification Procedure² 

On 17 November 2025, the Ministry of Coal invited public comments on proposed amendments to the notification procedure under Section 7 of the Coal Bearing Areas (Acquisition and Development) Act, 1957 (“CBA Act”).

Under Section 7 of the CBA Act, the Central Government notifies its will to coal deposit-rich land. Currently, notifications specify only the outer boundary and plot/khasra numbers, without naming recorded title-holders. As land titles are not frozen at the time of notification, subsequent changes in land records have led to widespread title disputes, delays in compensation, and a significant backlog of cases before tribunals under the CBA Act. Additionally, the Ministry has proposed to include the names of recorded title-holders in Section 7 notifications. With digital land records, GIS-based mapping, and technology-enabled verification widely available, plot-wise details and title-holder names can be obtained from revenue authorities before issuing notifications. 

If implemented, this reform is expected to reduce litigation risk for coal developers and expedite project timelines by minimising title disputes at the acquisition stage 

3. Biological Diversity (Access to Biological Resources and Knowledge Associated thereto and Fair and Equitable Sharing of Benefits) Regulations, 2025.³

The 2025 Regulations are issued by the National Biodiversity Authority (“NBA”) under section 64 read with sections 18(1) and 21(4) of the Biological Diversity Act, 2002, replaces 2014 Guidelines, and came into effect on 1 November 2025. The Regulations establish a comprehensive benefit-sharing framework for foreign and Indian entities accessing biological resources and associated traditional knowledge for: 

a. Commercial purpose; 

b. Research purpose; and  

c. commercialization of intellectual property rights. 

Benefit sharing can be paid in monetary or non-monetary terms: 

• Monetary benefits - Upfront, one-time, or royalty-based payments; contributions to biodiversity funds; and investment in Indian R&D or joint ventures. 
• Non-monetary benefits - technology transfer, infrastructure and capacity building, conservation activities, and collaborative research with Indian institutions. 

The benefit-sharing amount is calculated as a percentage of the annual gross ex-factory sale price (excluding taxes), tiered by annual turnover: 

• Up to ₹5 crore: Nil 
• Above ₹5 crore to ₹50 crore: 0.2% 
• Above ₹50 crore to ₹250 crore: 0.4% 
• Above ₹250 crore: 0.6% 

The Regulations provide an exemption for persons manufacturing products containing medicinal plants, where benefit-sharing payments shall not be payable. Additionally, the NBA may waive benefit-sharing requirements for genuine academic research. 

High-value and threatened species: The Regulations place emphasis on biological resources with high economic or conservation value, such as sandalwood. For threatened species, benefit sharing is set at a minimum of 5% of the sale/auction price as an upfront payment, or 20% above the standard rate. 

Intellectual property-based commercialisation: Where biological resources are used for IP rights, benefit sharing shall be up to 1% of sales if the applicant commercialises the IP directly, or up to 5% of fees/royalties if licensed to a third party. This increases by 25% if traditional knowledge is involved. 

4. MNRE issues Standard Operating Procedure (SOP) for the Approved List of Models and Manufacturers – Wind (ALMM-Wind) and Wind Turbine Components (ALMM-WTC)⁴ 

On 29 October 2025, the Ministry of New and Renewable Energy (MNRE) released a comprehensive Standard Operating Procedure (SOP) governing the enlistment of wind turbine models and their major components under the ALMM-Wind (Approved List of Models and Manufacturers for Wind) and ALMM-WTC (Approved List of Models and Manufacturers for Wind Turbine Components) frameworks. This SOP follows the July 2025 amendment renaming the erstwhile Revised List of Models and Manufacturers (RLMM) and introducing mandatory domestic sourcing requirements for major wind turbine components. 

Wind turbines can only be installed in India if both the turbine model (ALMM-Wind) and its major components (ALMM-WTC) are on the approved lists, creating a two-tier approval system aimed at ensuring quality standards and promoting domestic manufacturing. 

ALMM-Wind: Turbine Model Certification: Manufacturers seeking to install wind turbines in India must first obtain a Type Certificate from an accredited Certification Body, validating the turbine's design, safety, and performance. The ALMM-Wind Committee evaluates applications based on:

• technology architecture; 
• quality assurance processes; and,  
• documented performance data 

ALMM-WTC: Component-Level Approvals: The Type Certificate must list approved vendors for five major components:

• blades;  
• towers;  
• generators;  
• gearboxes; and,  
• special bearings (main, pitch, and yaw).  

Each component manufacturer must undergo a physical facility inspection by an MNRE-appointed technical team before being listed on ALMM-WTC. The inspection fee amounts to ₹1.5 lakh (USD 1,700) per component type, plus taxes and travel expenses. 

New Models vs. Variants: To prevent unnecessary proliferation of listings, the SOP distinguishes between new turbine designs and minor modifications:

• New Model: Requires rotor diameter variation ≥2% and rated power variation ≥10%, or a fundamentally different design (e.g., different generator technology or drive train configuration). 
• Variant: Any modification below these thresholds is treated as an update to an existing listing. 

All data control and research centres for wind turbines must now be located within India, addressing cybersecurity concerns in critical energy infrastructure. The two-tier approval system strengthens opportunities for Indian component manufacturers while requiring foreign suppliers to establish local inspection-compliant facilities or partner with listed Indian vendors.

5. Comprehensive Policy for Co-firing of Biomass pellets [including Torrefied Charcoal made from Municipal Solid Waste (MSW) in Coal based Thermal Power Plants⁵

The Ministry of Power issued a new comprehensive policy for co-firing of biomass pellets in coal-based thermal power plants (“TPPs”), effective from 7 November 2025, superseding previous guidelines. This policy expands the scope to include torrefied charcoal made from Municipal Solid Waste (“MSW”) alongside agricultural biomass.

The policy requires all TPPs to implement co-firing starting from Financial Year 2025-26. Thermal power plants within the National Capital Region (NCR) must use a 7% annual blend by weight, comprising 5% biomass pellets and an additional 2% from either biomass pellets or torrefied charcoal from MSW. For TPPs in all other regions, the requirement is a 5% annual blend from either fuel source. 

Types of Biomass Waste Allowed:

• Agro-Residues: Stubble, straw, husk, shells from crops like paddy, maize, cotton, mustard, etc. 
• Other Biomass: Bamboo, horticulture waste, grass, etc. 
• MSW: Torrefied charcoal produced from municipal solid waste. 
• Pellet Types: Plants can use non-torrefied, semi-torrefied, or fully torrefied pellets based on technical suitability. 

Renewable Consumption Obligation (RCO) Compliance: Distribution companies (Discoms) can use co-fired generation to meet their RCO under the Energy Conservation Act, 2001. Additionally, TPPs located in the NCR and adjoining areas are mandated to source at least 50% of the raw material for pellets exclusively from paddy stubble and crop residue from those same areas.

Power plants may seek exemptions, which will be reviewed on a case-by-case basis by a committee headed by the Central Electricity Authority (CEA). The policy is also applicable to TPPs with CFBC boilers, broadening its scope.

6. NMCG Approves Research and Infrastructure Projects for Ganga Basin⁶

The 67th Executive Committee (EC) of the National Mission for Clean Ganga (NMCG), under the Ministry of Jal Shakti, on 17 November 2025 approved multiple research and pollution abatement initiatives aimed at building the scientific foundation for long-term basin planning. 

Research Initiatives: 

• Glacier Monitoring (₹3.98 crore / USD 450,000): Study of glacier retreat and melt-runoff changes in the Upper Ganga Basin, including assessment of flash flood and Glacial Lake Outburst Flood (GLOF) risks.
• Digital Twin for Ganga Basin (₹3.31 crore / USD 375,000): Development of a real-time digital replica of the river basin using artificial intelligence (AI) and satellite remote sensing for predictive water management.
• SONAR Riverbed Survey (~₹3 crore / USD 340,000): High-resolution underwater mapping of 1,100 km from Bijnor to Ballia regions to support sediment management and long-term restoration of the Ganga.
• Groundwater Recharge (₹2.43 crore / USD 275,000): Construction of Managed Aquifer Recharge (MAR) structures along paleochannels between Kaushambi and Kanpur regions.

These initiatives represent a shift towards digital and technology-driven solutions under the Ministry of Jal Shakti, aligned with the government's emphasis on sustainable water resource management and environmental restoration.

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