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2 December 2025

Infrastructure, Projects And Energy Newsletter | August-October 2025

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We are pleased to present the third edition of the Infrastructure, Projects and Energy Newsletter. This edition captures the major judicial pronouncements and key regulatory developments across the renewable energy, road, electricity, power, oil and gas sectors. Through this newsletter, we seek to highlight the shifting regulatory and legal frameworks and equipping stakeholders with strategic insights.

Judicial Pronouncements

Supreme Court Upholds Strict Enforcement of PPA Terms, Developers Cannot Cite State Transmission Utility Delays to Escape PPA Deadlines

A division bench of the Supreme Court ("SC"), in a judgment dated August 25, 2025, held that the terms of a Power Purchase Agreement ("PPA") must be strictly construed, and a power developer cannot be excused from its contractual obligations due to delays caused by a state-owned transmission utility, especially when the developer fails to invoke the specific remedies available in the contract.

The dispute arose from a PPA between Chamundeshwari Electricity Supply Company Ltd. ("CESC"), a state distribution licensee, and Saisudhir Energy, a solar power developer. The developer failed to achieve the Commercial Operation Date ("COD") within the stipulated timeline because the state transmission utility, Karnataka Power Transmission Corporation Limited ("KPTCL"), had not completed the necessary power evacuation infrastructure. Consequently, CESC encashed the developer's performance bank guarantee. The Karnataka Electricity Regulatory Commission ("KERC") and the Appellate Tribunal for Electricity ("APTEL") ruled in the developer's favour, holding that the delay constituted a 'Force Majeure' event and ordered the restoration of the bank guarantee and an extension of timelines. CESC filed the present appeal against these orders.

The SC held that regulatory bodies cannot rewrite the terms of a concluded commercial contract under the guise of equity. The Court noted that the PPA provided specific mechanisms for seeking relief, such as an extension of time under Article 5.7 of the PPA, which the developer failed to formally invoke. Furthermore, the finding of 'Force Majeure' was set aside because the developer had not issued the contractually mandated notice, which was a pre-condition for claiming such relief under Article 14.5 of the PPA. The SC concluded that since the developer did not commence supply by the scheduled date and failed to secure a formal extension or validly claim force majeure, CESC was well within its contractual rights to encash the performance security as per Article 4.4 of the PPA.

DLL Analysis - Project delays due to the non-completion of associated infrastructure by government agencies are a common challenge for private developers. This judgment serves as a critical precedent, emphasizing that developers must diligently adhere to the contractual procedures for seeking relief and cannot assume automatic extensions or protection. The ruling provides significant clarity and certainty for distribution licensees, upholding their right to enforce performance securities to ensure project discipline. It underscores that risks are to be managed within the four corners of the agreement, and regulatory forums cannot alter the commercial bargain struck between the parties.

Case Title: Chamundeshwari Electricity Supply Company Ltd. (CESC) vs. Saisudhir Energy (Chitradurga) Pvt. Ltd. & Anr., 2025 INSC 1034

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Supreme Court Reaffirms: Tariffs in PPAs Require Regulatory Commission Approval, Private Amendments Invalid

A division bench of the Supreme Court ("SC"), in a judgment dated August 29, 2025, held that a generating company and a distribution licensee cannot privately amend a Power Purchase Agreement ("PPA") to alter tariffs without the express review and approval of the State Electricity Regulatory Commission.

The dispute arose after M/s. KKK Hydro Power Limited ("Appellant") and the Himachal Pradesh State Electricity Board ("HPSEB") executed a supplementary PPA in 2010, enhancing the tariff for a 4.90 MW hydro project from a fixed rate of Rs. 2.50/kWh to Rs. 2.95/kWh. This was done without seeking approval from the Himachal Pradesh Electricity Regulatory Commission ("Commission"). When the HPSEB failed to pay arrears at the higher rate, the appellant approached the Commission, which dismissed the petition, declaring the supplementary PPA unenforceable. The Appellate Tribunal for Electricity ("APTEL") partially allowed the appeal, directing a 'weighted average' tariff for the project, by applying the old tariff to the original 3 MW capacity and the regulated tariff to the augmented 1.90 MW capacity. The appellant filed the present appeal seeking the enhanced tariff for the entire project.

The SC held that under Section 86(1)(b) of the Electricity Act, 2003, the regulation of the electricity purchase price is the exclusive domain of the State Commission. Therefore, the supplementary PPA executed by the parties without the Commission's approval was invalid.

DLL Analysis - This judgment is an affirmation of the powers of Electricity Regulatory Commissions in tariff determination. It sends a clear message that licensees and generating companies cannot circumvent the regulatory process through private agreements to set or modify tariffs. This decision reinforces the legislative intent behind the Electricity Act, 2003, which is to ensure transparency, fairness, and regulatory scrutiny in the power procurement process. By invalidating tariffs fixed without regulatory approval, the ruling protects consumer interests from potentially arbitrary price hikes and ensures that the financial health of distribution utilities is managed under the watchful eye of the regulator.

Case Title: M/s. KKK Hydro Power Limited vs. Himachal Pradesh State Electricity Board Limited and others, 2025 INSC 1057

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APTEL's Judgment Reinforces 'Must Run' Rights for Renewables, Mandates Transparency and Accountability in Grid Curtailment

The Appellate Tribunal for Electricity ("APTEL"), by its judgment dated September 11, 2025, allowed the appeal of Tanot Wind Power Venture Pvt. Ltd. ("Tanot"), setting aside the order of the Rajasthan Electricity Regulatory Commission ("RERC") dated November 29, 2017. The case arose from frequent and arbitrary backing down instructions issued by the State Load Dispatch Centre ("SLDC"), Jaipur, directing Tanot's 120 MW wind power project to reduce or cease generation, even when grid conditions were stable, and demand remained high. These curtailments, which Tanot contended were not necessitated by grid security concerns, directly conflicted with the project's "Must Run" status under the RERC (Grid Code) Regulations, which mandate priority dispatch for renewable energy.

APTEL held that the curtailments violated Regulation 7.8.1 of the Rajasthan Electricity Grid Code, 2008, which grants wind and solar generators "Must Run" status. The Tribunal noted that most backing down events occurred when system frequency and voltage levels were within permissible limits accordingly, the present instructions to reduce or cease wind power generation were not justified on technical or grid security grounds. It further underscored that renewable energy curtailment cannot be routine or commercially motivated and directed the state authorities to ensure adherence to grid code obligations going forward.

APTEL directed the Rajasthan Electricity Regulatory Commission to compensate Tanot for financial losses caused by the unlawful curtailment. The Tribunal set aside RERC's previous dismissal of compensation claims and remanded the matter for a detailed inquiry and determination of consequential relief within three months.

DLL Analysis: The decision strengthens the regulatory protection accorded to renewable generators by reaffirming that "Must Run" status cannot be diluted through arbitrary operational instructions. It reinforces the accountability of system operators and transmission utilities in maintaining grid integrity and transparency. APTEL's ruling provides an important precedent for ensuring that renewable energy generators receive fair treatment and timely compensation for losses caused by avoidable curtailments and infrastructure lapses.

Case title: Tanot Wind Power Venture Pvt. Ltd. v. Rajasthan Electricity Regulatory Commission & Ors., Appeal No. 108 of 2018, Judgment dated September 11, 2025.

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APTEL Upholds CERC's Rejection of Outdated Tariff for Battery Storage Pilot Project, Sets Market-Alignment Precedent

The Appellate Tribunal for Electricity ("APTEL"), by its judgment dated September 12, 2025, dismissed appeals filed by both JSW Renew Energy Five Ltd. ("JSW") and the Solar Energy Corporation of India Ltd. ("SECI"). The appeals arose out of CERC's refusal to adopt the discovered tariff for a 500 MW/1000 MWh stand-alone Battery Energy Storage System ("BESS") pilot project, citing inordinate delays and a sharp decline in market prices for battery storage following the original auction.

CERC had observed that structural and regulatory delays (with agreements signed up to 245 days late) allowed developers to potentially procure batteries at much lower costs while still charging consumers at the higher, original tariff effectively resulting in "unintended gains to developers and wrongful loss to the public at large". Notably, subsequent SECI auctions discovered BESS tariffs 35-50% lower than the original pilot project bid, highlighting rapid cost deflation in the sector.

APTEL held that regulatory authorities are within their rights to examine whether discovered tariffs remain "market-aligned" at the time of adoption and to reject outdated tariffs that no longer reflect fair pricing or consumer interest. The Tribunal noted that JSW had no vested right until regulatory adoption and emphasized that consumer interest must be safeguarded and that undue delay combined with rapid technology cost decline justify rejection of outdated tariffs. The appeals by JSW and SECI arguing that discovered tariffs from competitive bidding ought to be honored regardless were dismissed.

DLL Analysis: This landmark ruling underscores the need for timely adoption processes and robust regulatory scrutiny in emerging technologies like battery storage and hydrogen, where costs can fall rapidly. The judgment prioritizes consumer interest and market-aligned pricing while signaling to developers and agencies that discovered tariffs may not be shielded from reassessment when there are material delays or sectoral shifts. This landmark ruling reaffirms that tariff decisions must be timely and market-reflective to ensure equitable outcomes for consumers, laying the groundwork for robust regulatory oversight in evolving energy markets.

Case title: JSW Renew Energy Five Ltd. & Solar Energy Corporation of India Ltd. v. Central Electricity Regulatory Commission & Ors., Appeal Nos. 26 & 54 of 2025, Judgment dated September 12, 2025.

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Supreme Court Upholds Coal India's 2006 Interim Coal Policy And 20% Price Surcharge on Non-Core Sectors

The Supreme Court ("SC") on September 12, 2025, upheld Coal India Limited's ("CIL") Interim Coal Policy of 2006, which imposed a 20% surcharge on coal supplied to the non-core sector. This judgement set aside the Calcutta High Court's 2012 ruling that had invalidated the policy.

CIL argued the surcharge was essential to maintain coal supply and financial viability for sustained production, prioritizing core sectors such as power and steel critical for the nation's infrastructure and economy. The SC agreed, confirming Coal India's competence under the Colliery Control Order, 2000, and upholding the pricing differential as a reasonable and valid classification under Article 14 of the Indian Constitution.

The Court rejected claims that the surcharge was arbitrary or an attempt at profiteering, clarifying that ensuring equitable resource distribution and market stability justified the policy. It dismissed the respondents' demands for refund, emphasizing the need to balance resource availability with public welfare and industrial growth.

DLL Analysis: This ruling strengthens regulatory certainty in coal pricing and allocation policies, enabling Coal India to maintain production capacity vital to national energy security and industrial supply chains. By affirming the legitimacy of differentiated pricing, the judgment helps ensure stable coal availability to critical sectors, supporting sustained industrial and infrastructure development. The decision also highlights the government's role in responsibly managing natural resources to serve broader social and economic interests.

Case title: Coal India Ltd. And Ors. v. M/S Rahul Industries And Ors., 2025 INSC 1103, Judgment dated September 12, 2025.

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Regulatory Updates

Ministry of Power Issues Draft Rules for Compliance under Energy Conservation Act, 2001.

The Ministry of Power issued the draft Energy Conservation ("Compliance Enforcement") Rules, 2025 ("Rules") on August 4, 2025, for monitoring, reporting, and enforcement of compliance under the Energy Conservation Act, 2001 ("Act").

The Rules shall apply to manufacturers, importers, designated consumers, and any other person or entity as specified in the Act. The Rules designate the Bureau of Energy Efficiency ("Bureau") as the reporting, verifying and penalizing authority for such entities. The Rules entrust the Bureau with the responsibility to seek information, verify compliance with the prescribed norms and submit certified reports to the Central Government. The draft Rules provide that the Bureau shall be responsible for compliance enforcements with the norms and standards provided by the Central Government and in case of any shortfall or non-compliance, the norms and standards provided by the Central Government under the Act shall take precedence over cumulative norms at the State level, thereby ensuring uniformity. The Bureau shall also have the responsibility to make regulations and issue guidelines for implementation of the Rules.

The Rules also designate the Adjudicating Officer of the State Electricity Regulatory Commission for adjudging for failure to comply with the provisions of the Act based on the location of the concerned entity. The Rules prescribe for the penalties payable by the entities for non-compliance to be credited into the Central Energy Conservation Fund as referred under the Act, out of which ninety percent shall be transferred to the Consolidated Fund of the State Government and ten percent to the Central Government.

DLL Analysis: The draft rules issued by the Ministry of Power strengthen the enforcement framework under the Energy Conservation Act, 2001 by clearly defining accountability for non-compliance by the entities. By designating the Bureau of Energy Efficiency as the authority to oversee reporting, verification and penalization, the government is centralizing oversight to ensure uniform implementation across manufacturers and consumers covered under the Act. At the same time, linking adjudication to state commission officers ensures that violations are addressed at the local level, providing jurisdictional clarity. The requirement that penalties be directed into the Central Energy Conservation Fund and the State Government Consolidated Fund reinforces the principle that enforcement revenues should directly support energy efficiency initiatives.

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MNRE Issues Revised Guidelines for Green Hydrogen Pilot Projects

Ministry of New and Renewable Energy, Hydrogen Division on August 4, 2025, issued revised Guidelines for implementation of Pilot projects for production and use of Green Hydrogen using innovative methods ("Guidelines"). The Guidelines targets applications in residential, commercial, localized community, decentralized/non-conventional and any new sector or technology not covered in previous mission schemes.

The Guidelines supports innovative models for floating solar based Green Hydrogen production, biomass Green Hydrogen production and production of Green Hydrogen from wastewater. The Guidelines focuses on utilisation of Green Hydrogen and its derivatives as fuel in cooking, heating, off-grid electricity generation, off road vehicles on a pilot basis. Another key focus is validating the technical feasibility and performance of hydrogen as a fuel for household and commercial appliances, as well as for community-level and city gas applications.

The Guidelines, with a budget of Rs. 200 crores until FY 2025-26, will be implemented by designated Scheme Implementing Agencies ("SIAs"). The SIAs shall be entitled to a fee of 0.5% of the total amount sanctioned ensuring that the expenditure for the scheme including service charge does not exceed Rs. 200 crores.

The Guidelines is structured in two parts:

Part A: With a total financial support of Rs.100 crore, this part will fund biomass-based and other technology-based pilot projects, with a maximum support of Rs. 25 crore per project.

Part B: Also allocated Rs. 100 crores, this part is specifically designed to support startups developing innovative hydrogen production/utilization technologies, with a maximum support of Rs. 5 crore per project.

The Central Financial Assistance ("CFA") will cover up to 100% of the total equipment cost for government organizations and 80% for private entities. The funds will be disbursed in milestones, starting with a 20% release upon the issuance of a Letter of Award. The Guidelines will not fund operating expenses such as the cost of renewable electricity, land, or water.

Overall monitoring of the Guidelines and projects undertaken will be carried by a high-level Steering Committee chaired by the Secretary, MNRE, and a Project Appraisal Committee ("PAC") chaired by the Mission Director of the National Green Hydrogen Mission. The Guidelines also include provisions for penalties in case of delays and require Executing Agencies ("EAs") that fail to utilize grants for their intended purpose under this Guidelines to refund the entire amount with interest.

DLL Analysis:The MNRE's Revised Guidelines for pilot projects on Green Hydrogen mark a deliberate effort to broaden the scope of India's hydrogen mission beyond industrial and transport applications into residential, community, and decentralized use cases. This initiative represents a strategic step under the National Green Hydrogen Mission to accelerate India's transition to clean energy, reduce dependence on fossil fuels, and establish the nation as a global leader in Green Hydrogen technology. By supporting innovative production pathways such as floating solar, biomass-based methods, and hydrogen from wastewater, the guidelines encourage technological diversification and resource optimization. At the same time, the pilot focus on applications like cooking, heating, off-grid power, and off-road mobility reflects an ambition to test hydrogen's viability at the grassroots level and integrate it into everyday energy use.

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CERC Issues Central Electricity Regulatory Commission (Connectivity and General Network Access to the Inter-State Transmission System) (Third Amendment) Regulations, 2025

The Central Electricity Regulatory Commission ("CERC") issued the Third Amendment to the Connectivity and General Network Access ("GNA") Regulations, 2022, on August 31, 2025, refining the framework governing connection and access rights to the inter-state transmission system (ISTS).

Key highlights of the Amendment include:

  1. Introduction of new definitions such as "cluster of ISTS substations" to streamline planning and grouping of substations based on geographical and technical criteria, improving system efficiency.
  2. Formal recognition of "connectivity grantee" status for entities with signed connectivity agreements, strengthening regulatory clarity.
  3. New provisions enabling differentiated injection scheduling rights during "solar hours" and "non-solar hours," facilitating better alignment of renewable energy generation patterns with grid operation.
  4. Revised rules for withdrawal or partial withdrawal of connectivity applications, with clear treatment of bank guarantees to ensure accountability and reduce speculative applications.
  5. Enhanced flexibility for renewable energy generating stations ("REGS") and energy storage systems ("ESS") to specify and schedule maximum injection and drawl quantities within granted connectivity limits.
  6. Procedures for change of renewable energy source within connectivity quantum, allowing developers to adapt projects to resource availability and technology changes.
  7. Clear processes for additional capacity applications without requiring new network augmentation, encouraging capacity expansion within existing permissions.
  8. Strengthened documentation, land requirement, and financial closure compliance to improve transparency and project delivery certainty.

DLL Analysis: This amendment marks a significant step in optimizing India's interstate transmission connectivity framework to support the increasing share of renewable generation and energy storage. The introduction of solar and non-solar hour access rights enables more efficient utilization of transmission infrastructure aligned with variable renewable output. Revised procedures for application withdrawal and bank guarantees enhance discipline among applicants and help reduce congestion in connectivity queues. By accommodating source changes and capacity augmentations within connectivity grants, the regulations offer improved flexibility to developers navigating dynamic market and technology environments. Overall, these amendments facilitate smoother renewable integration, better planning, and more reliable grid operation key to India's ambitious renewable energy transition and decarbonization goals.

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Ministry of Power Withdraws URET Mechanism for the Dissolution of "Solar Power Central Pool" and "Solar Wind Hybrid Central Pool"

The Ministry of Power issued an office memorandum dated August 1, 2025, announcing the withdrawal of the Uniform Renewable Energy Tariff ("URET") mechanism and the associated 'Solar Power Central Pool' and 'Solar-Wind Hybrid Central Pool' originally established from February 15, 2024, through OM No. 13/05-2023-RCM/NRE.

The URET mechanism was originally introduced to provide a uniform, averaged-out tariff to procurers, shielding them from the volatility of declining bid-discovered prices. However, the Ministry noted that the mechanism had an unintended consequence: procurers became reluctant to sign Power Sale Agreements ("PSAs") due to uncertainty over the pooled tariff, which was set for a three-year period.

In response to these concerns from Renewable Energy Implementing Agencies ("REIAs") and developers, the Ministry decided to scrap the URET framework. Importantly, the Ministry has clarified that all bids received and Letters of Award issued under the URET mechanism will remain valid. These projects can now proceed with the signing of Power Purchase Agreements ("PPAs") and PSAs on a standalone basis, based on their original bid-discovered tariffs.

DLL Analysis: The dissolution of the URET mechanism reflects an important policy recalibration that prioritizes market confidence over rigid tariff structures. While the original intent of URET was to provide price stability amid falling bid rates, its three-year uniform tariff proved too inflexible for procurers facing dynamic cost structures and evolving demand patterns. While the URET was conceived to de-risk procurement for state distribution companies ("Discoms"), it inadvertently created uncertainty for procurers because the pooled tariff was fixed for a three-year period, which could become less favorable compared to actual bid-discovered prices over time. This mismatch made procurers hesitant to sign power sale agreements, slowing down project progress. Procurers clearly prefer the long-term price certainty of a 25-year PPA based on a specific bid-discovered tariff over a pooled tariff that could fluctuate.

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Geothermal Energy Policy 2025: India Unveils National Policy on Geothermal Energy

The Ministry of New and Renewable Energy ("MNRE") announced the National Policy on Geothermal Energy (2025) ("Policy"), on September 17, 2025, a landmark move to bring India's untapped geothermal resources into its clean energy mix. With the 2070 Net Zero target in sight, the policy aims to diversify renewable energy sources beyond solar and wind, making geothermal a reliable option for power and heat. The policy provides a comprehensive framework to promote exploration, development and utilization of geothermal energy in India.

The Policy outlines a comprehensive strategy for developing India's geothermal sector, with MNRE holding regulatory and stewardship responsibilities. It aims to integrate geothermal energy with India's Net Zero and renewable energy targets, promoting diverse applications such as electricity generation, heating/cooling, agriculture, tourism, and desalination. The policy emphasizes technological innovation by promoting research and development, including hybrid geothermal-solar plants, retrofitting abandoned oil wells and Enhanced Geothermal Systems, alongside local innovation, joint ventures, and the repurposing of existing oil/gas infrastructure. It also stresses extensive collaboration with international bodies, pioneering nations, state governments, and research institutions to build a robust public-private ecosystem and enhance capacity through knowledge sharing and human resource development. As an initial step, MNRE has already sanctioned five pilot and resource assessment projects to explore India's geothermal potential.

Currently the Geological Survey of India ("GSI") has identified 10 geothermal provinces in India namely, (i) Himalayan Geothermal Province; (ii) Naga-Lusai; (iii) Andaman Nicobar Islands; (iv) Son-Narmada Tapi (SoNaTa); (v) West Coast; (vi) Cambay Graben; (vii) Aravalli; (viii) Mahanadi; (ix) Godavari; (x) South Indian Cratonic. The Ministry shall facilitate the creation of a geothermal resource data repository through Intergovernmental/inter-agency collaboration with various Ministries.

DLL Analysis: This Geothermal Energy Policy signals a strategic intent to diversify India's renewable energy mix beyond solar and wind. By designating MNRE with clear regulatory oversight and focusing on integration with Net Zero goals, the policy establishes a strong framework for systematic development. The emphasis on diverse applications, from power generation to heating and agriculture, highlights a pragmatic approach to leveraging geothermal's multi-faceted benefits, which is crucial for maximizing its economic viability. Furthermore, promoting technological innovation and strategic collaborations, including repurposing oil and gas infrastructure, demonstrates foresight in utilizing existing assets and expertise. The sanctioned pilot projects represent concrete first step, underscoring the government's commitment to translate policy objectives into practical, on-ground development and to unlock geothermal energy's potential as a reliable, sustainable contributor to India's clean energy transition.

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Electricity (Amendment) Rules, 2025 Notified by Ministry of Power

The Central Government through the Ministry of Power, on September 19, 2025, notified the Electricity (Amendment) Rules, 2025 ("Amendment Rules") on September 19, 2025, in exercise of the powers conferred by Section 176 of the Electricity Act, 2003. These Rules aim to enhance the regulatory framework for electricity generation, transmission, distribution, and trading in India to align with evolving market dynamics and policy priorities.

The key objectives include

  1. recognizing and integrating Energy Storage Systems ("ESS") as independent or integrated components in generation, transmission, and distribution;
  2. enabling diverse ownership, operation, leasing, and capacity sharing models for ESS involving generators, licensees, consumers, system operators, and independent service providers;
  3. clarifying legal status and scheduling norms for co-located and non-co-located energy storage systems; and
  4. facilitating sale, leasing, or rental of energy storage capacity to consumers, utilities, and Load Despatch Centres.

The Amendment Rules apply to all licensees, generating companies, transmission utilities, distribution licensees, traders, aggregators, consumers, and other market participants within India. The Amendment Rules introduce specific provisions to facilitate the participation of battery energy storage systems ("BESS"), demand response, and electric vehicles ("EVs") in ancillary services and electricity markets. They also set out updated requirements for forecasting, scheduling, and metering of renewable and distributed generation to enhance grid stability and ensure efficient market operations.

DLL Analysis:These Amendment Rules represent a comprehensive update to India's power sector regulations. By providing a consistent legal framework for energy storage and distributed resources, the Rules accelerate clean energy integration and grid modernization. This regulatory clarity fosters investment, innovation, and competition across India's evolving electricity markets, supporting a sustainable and reliable energy future.

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Ministry of Power Issues Revised Renewable Consumption Obligation ("RCO") Notification, 2025

On September 27, 2025, the Ministry of Power issued a revised Gazette Notification specifying the minimum share of renewable energy consumption for designated consumers, including distribution licensees, open access consumers, and captive users, under the Energy Conservation Act, 2001.

Key highlights include:

  1. The Renewable Consumption Obligation mandates a gradual increase in the minimum share of renewable energy in total electricity consumption, rising from 29.91% in FY 2024-25 to 43.33% by FY 2029-30. This total includes specified targets for various categories such as wind, hydro, distributed renewable energy projects (up to 10 MW capacity), and other renewable sources.
  2. Multiple compliance pathways for designated consumers including direct renewable consumption, purchase of Renewable Energy Certificates, or payment of a buyout price.
  3. Mandatory submission of certified energy accounts starting FY 2024-25, with annual compliance reports and penalties for non-compliance under Section 26 of the Energy Conservation Act, 2001.
  4. Funds collected through the buyout mechanism will be channeled to state-level renewable energy development programs to encourage clean energy capacity growth.

DLL Analysis: This notification strengthens India's clean energy transition by ensuring a steadily increasing share of renewable energy in the consumption mix of major power consumers. It reinforces accountability with robust monitoring and enforcement provisions. The approach supports decentralization of renewable deployment and creates a stronger market for renewable energy certificates and storage solutions. The notification complements other regulatory reforms advancing renewable integration and sustainability goals.

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Ministry of Heavy Industries Issues Operational Guidelines for EV Public Charging Stations Under PM E-DRIVE Scheme

On September 26, 2025, the Ministry of Heavy Industries ("MHI"), Government of India, released Operational Guidelines to support deployment of up to 72,300 public electric vehicle charging stations ("EVCS") nationwide under the PM E-Drive Scheme. This initiative forms part of a Rs. 10,900 crores push to accelerate EV adoption by expanding accessible charging infrastructure.

Key highlights:

  1. A dedicated Rs. 2,000 crore subsidy pool supports charging infrastructure installation, covering upstream infrastructure and EV supply equipment across various categories.
  2. Subsidy model offers up to 100% support on Government premises, 80% for high-traffic public locations (airports, metro stations, fuel retail outlets), and 80% on upstream infrastructure for commercial and highway locations. Battery swapping and charging stations also receive 80% subsidy.
  3. Eligible entities include Government of India ("GoI") ministries, Central Public Sector Enterprises ("CPSEs"), States/UTs, and their nodal agencies coordinating demand aggregation and proposal submission.
  4. Prioritized deployment targets million-plus cities, smart cities, state capitals, metro-linked satellite towns, and major highways with high vehicular volumes and logistical significance.
  5. Bharat Heavy Electricals Limited ("BHEL") serves as Project Implementation Agency ("PIA") coordinating evaluation, deployment oversight, and development of a 'National Unified Hub' for charger integration and real-time data sharing.

DLL Analysis: This operational framework signals a major governmental commitment to build a comprehensive and user-friendly EV charging ecosystem. The large-scale rollout promises to reduce range anxiety, facilitate ubiquitous EV use, and significantly push India's sustainable mobility goals. By supporting diverse vehicle segments and prioritizing equitable access, the PM E-Drive Scheme will be central to India's clean transport revolution.

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MNRE Issues Draft Guidelines for Series Approval of Storage Batteries Under Solar Systems Order 2025

On September 29, 2025, the Ministry of New and Renewable Energy ("MNRE") released draft guidelines to facilitate testing, certification, and series approval of storage batteries (including lead-acid, lithium-ion, and nickel-based chemistries) for compulsory registration under the Solar Systems, Devices and Component Goods Order, 2025.

The guidelines apply the Indian Standard IS 16270:2023 for secondary cells and batteries used in solar photovoltaic applications, laying down product family definitions to group similar models for efficient approval. They specify the quantity and sequence of tests per battery category to ensure quality, safety, and reliability. Manufacturers must mark batteries permanently with key details (manufacturer, nominal voltage, rated capacity, manufacturing date and cell designation), and provide testing labs with charging protocols.

DLL Analysis: This regulatory development strengthens India's quality control ecosystem for solar battery technologies, minimizes duplication in testing, and promotes uniform standards alignment with global best practices. These draft guidelines will streamline compliance and enhance quality assurance across solar energy storage products, supporting India's renewable energy targets and boosting confidence in battery performance and safety. It underpins robust deployment of solar storage solutions essential for grid stability and clean energy reliability.

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Central Electricity Authority Issues Draft Amendment to Technical Standards Regulations, 2025

The Central Electricity Authority ("CEA") issued the Draft Central Electricity Authority (Technical Standards for Construction of Electrical Plants and Electric Lines) (2nd Amendment) Regulations, 2025, in October 2025, inviting public comments.

The draft updates technical standards for renewable energy generating stations and battery energy storage systems ("BESS"). It mandates that equipment ratings be suitable for continuous operation and requires developers to install automatic weather stations measuring wind speed, temperature, humidity, and atmospheric pressure. The draft also contemplates installation of phasor measurement units as per upcoming CEA guidelines for enhanced grid monitoring.

Specific technical norms for solar power plants, load considerations, and BESS major equipment specifications are included to ensure design safety, reliability, and grid compatibility.

DLL Analysis: This amendment is significant for ensuring standardized, robust construction and operational norms for renewable energy and storage projects crucial to grid modernization. The technical standards will support improved grid stability, forecasting accuracy, and integration of emerging technologies, aligning with India's clean energy transition goals.

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Ministry of Environment Notifies Greenhouse Gases Emission Intensity Target Rules, 2025

On October 8, 2025, the Ministry of Environment, Forest and Climate Change ("MoEFCC") notified the Greenhouse Gases Emission Intensity ("GEI") Target Rules, 2025 emission intensity reduction regulations targeting four key industrial sectors: aluminium, cement, chlor-alkali, and pulp & paper.

The Rules set specific greenhouse gas emission intensity limits for industrial units across these sectors for the fiscal years 2025-26 and 2026-27. Facilities meeting targets earn tradable carbon credits under the domestic Carbon Credit Trading Scheme ("CCTS"), 2023, while non-compliant units must purchase credits or pay environmental compensation equal to twice the average credit price.

The GEI Target Rules operationalize the CCTS, advancing India's commitment to reduce emissions intensity of its GDP by 45% by 2030 under the Paris Agreement. The rules integrate rigorous monitoring, registration, and reporting requirements to ensure transparency and accountability.

DLL Analysis:These rules mark a historic milestone in India's climate governance by enforcing sector-specific, measurable emission thresholds and linking performance to a market-based carbon credit mechanism. They incentivize industrial efficiency improvements and support the scaling of low-carbon technologies. The framework balances environmental goals with economic growth, providing a clear pathway for India's decarbonization trajectory.

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