Clean Energy Newsletter

Set out below are some of the major recent developments in the clean energy sector in India:

1. Solar and Wind Power

ALMM – Solar Wafers

The Ministry of New and Renewable Energy, Government of India ("MNRE") on September 12, 2025 issued a draft amendment to the Approved List of Models and Manufacturers ("ALMM") Order, 2019, proposing the introduction of ALMM List-III for solar wafers, for stakeholder comments.

Some of the key features of the draft amendment are:

• ALMM List-III would be applicable from June 1, 2028
• ALMM List-III would not be issued unless it contains at least 3 wafer manufacturing units which must operate independently and would not be under common ownership or control, whether directly or indirectly, and the aggregate wafer manufacturing of such units is at least 15 GW per annum;
• all projects falling under the purview of ALMM would have to mandatorily source their solar photovoltaic ("PV") modules from models and manufacturers enlisted in ALMM List-I for solar PV modules and such solar PV modules in turn would have to use solar PV cells from amongst the models and manufacturers enlisted in ALMM List-II for solar PV cells, and such solar PV cells would have to use wafers from amongst the models and manufacturers enlisted in ALMM List-III for wafers; and
• projects which are exempted from using ALMM enlisted solar cells would automatically get exemption from using ALMM enlisted wafers.

ALMM – Solar PV Cells

MNRE pursuant to its successive orders, added further solar PV cell manufacturers to ALMM List-II, as follows:

• order dated September 23, 2025 added 2 new solar PV cells manufacturers, namely, M/s. TP Solar Limited and M/s. Tata Power Renewable Energy Limited, increasing the number of cell manufacturers to 11;
• order dated November 24, 2025, added 1 new solar PV cells manufacturer, M/s Websol Energy System Limited, increasing the number cell manufacturers to 12; and
• order dated December 15, 2025, added 1 new solar PV cells manufacturer, M/s. Waaree Energies Limited, increasing the number of cell manufacturers to 14.

On October 3, 2025, MNRE issued an advisory directing all government agencies in the renewable energy sector to ensure strict compliance with procurement rules and regulations, particularly in relation to bid timelines and adherence to the ALMM mandate for solar cells.

On December 19, 2025, MNRE issued an office memorandum clarifying that renewable power projects established for the exclusive purpose of supplying power to projects under SIGHT Mode-2A and Mode-2B would be exempt from the requirement to use solar PV cells listed under ALMM List-II, to the extent of the renewable power required for the capacity allocated under SIGHT Mode-2A or Mode-2B. This exemption would be applicable where the last date of bid submission for such projects falls on or before August 31, 2025, irrespective of the date of commissioning. MNRE has further clarified that the ALMM exemption granted under its earlier office memorandum dated May 27, 2024 would continue to remain valid, subject to the conditions specified therein. The ALMM relaxations would be considered and granted on a case-by-case basis upon receipt of a formal request from the developer and following due assessment.

ALMM – Solar PV Modules

MNRE pursuant to its order of November 25, 2025 added 9 new solar PV module manufacturers to the ALMM List-I for solar PV modules of October 13, 2025, increasing the number of module manufacturers to 205. Further, by its order dated December 22, 2025, MNRE (i) removed Emvee unit 1 located at 13/1, International Airport Road, Bettahalasur, Bengaluru – 562157; and (ii) updated the address of M/s. Sirius Solar Energy Systems Private Limited, in the ALMM List-I for solar PV modules.

On November 28, 2025, MNRE issued a draft order inviting stakeholder comments , proposing an increase in the minimum module-efficiency thresholds for enlistment under ALMM List-I for solar PV modules, in order to ensure that the list reflects commercially viable high-efficiency technologies, remains dynamic with sectoral advancements and restricts enlistment of low-efficiency or obsolete products.

ALMM – Wind

On October 29, 2025, MNRE issued a standard operating procedure ("SOP") governing the ALMM-Wind ("ALMM Wind") and the ALMM-Wind Turbine Components ("ALMM WTC"). The SOP has been introduced to standardise the procedure for enlistment of type-certified wind turbine models and major components, to ensure quality assurance, traceability, cyber-security compliance and to guide state nodal agencies, lenders, developers and investors. The SOP applies to all applications for enlistment of wind turbine models in ALMM Wind and major components (blades, tower, generator, gearbox and special bearings) in ALMM WTC, and links component enlistment to the approved component list contained in the turbine's type certificate.

Subsequently, on December 1, 2025, MNRE issued an office memorandum amending the Clause 8.1 (Performance Efficiency and Safety Issues) of the SOP. The original SOP, made prototype testing in India mandatory with immediate effect. However, the amendment, while encouraging manufacturers to conduct prototype testing in India, has deferred the mandatory requirement for a period of 2 years from December 1, 2025, subject to review.

Solar Parks

On September 17, 2025, MNRE through its office memorandum extended the implementation timeline of the Scheme for Development of Solar Parks and Ultra Mega Solar Power Projects by an additional 3 years, i.e., up to March 31, 2029 (financial year 2028–29). Importantly, new sanctions/ approvals for any available capacity under the said scheme would be accorded only until March 31, 2026.

2. Electricity Rules, Regulations and Orders

Electricity Act and Rules

The Central Electricity Authority ("CEA"), Ministry of Power, Government of India ("MoP") has pursuant to its circular dated September 10, 2025 clarified its earlier procedure for verification of captive status of inter-state projects . Pursuant to this circular, generating stations owned by special purpose vehicles ("SPVs") are required to intimate the details of the specific unit(s) earmarked for captive use to the verifying authority, the concerned distribution licensee, and the Regional/State Load Despatch Centre. The circular includes a prescribed format for disclosure, requiring details such as, name and address of the captive generating plant and SPV, total installed capacity, including any energy storage component; connection details (Central Transmission Utility/ State Transmission Utility and sub-station), area of operation of captive users, and specific unit(s) identified for captive use, supported by authenticated generation data.

On September 19, 2025, MoP notified the Electricity (Amendment) Rules, 2025 to permit developers or owners of energy storage systems ("ESSs") to sell, lease, or rent out storage capacity (in full or in part) to any consumer, utility, load despatch centre, or other authorised entity.

On September 23, 2025, MoP issued a draft amendment to Rule 3 of the Electricity Rules, 2005 ("Electricity Rules") for stakeholder comments by October 22, 2025. The proposed Electricity (Second Amendment) Rules, 2025 seek to clarify ownership and consumption conditions for captive projects. Pertinent to mention that this draft amendment has been amended and MoP has recently (in January 2026) issued draft amendment to the Electricity Rules in relation to captive power plants. We will cover this in our next edition of this clean energy newsletter.

On October 9, 2025, MoP issued a draft Electricity (Amendment) Bill, 2025 ("Electricity Bill") for stakeholder comments. The Electricity Bill proposes extensive reforms to the Electricity Act, 2003 ("Electricity Act"), focusing on tariff rationalisation, market development, regulatory efficiency, consumer protection, and stronger enforcement mechanisms.

Some of the key amendments proposed pursuant to the Electricity Bill are:

• new definitions of ESS, electric line authority, and manufacturing enterprise, and explicit inclusion of ESS within the power system ambit;
• a mandate that tariffs reflect the cost of supply and a specific requirement that cross-subsidies for railways, metro railways systems and manufacturing enterprises be eliminated within 5 years of commencement of the Electricity (Amendment) Act, 2025;
• empowering appropriate commissions to determine tariffs suo motu where applications are not filed in time so new tariffs take effect from the start of the next financial year;
• enabling the appropriate commissions to promote market-based platforms and novel market products, including non-transferable specific-delivery contracts for difference, to accelerate capacity addition;
• permission for distribution through own or shared networks (subject to a framework to be issued by the Central Electricity Regulatory Commission ("CERC")), and a provision allowing State Electricity Regulatory Commissions, in consultation with State Governments, to exempt a distribution licensee from the obligation to supply consumers whose maximum demand exceeds 1 MW, with a supplier-of-last-resort safeguard;
• a requirement that every proceeding before the appropriate commission be decided expeditiously, with an endeavour to dispose of the matter within 120 days and with reasons recorded for any delay;
• limitation of the assessment or look-back period for unauthorised electricity use to a maximum of 12 months from detection, thereby ensuring continuous monitoring, reducing discretion in assessments, and protecting consumers from retrospective penalties; and
• introduction of a specific penalty for shortfall in renewable purchase obligation compliance, empowering CERC, after hearing the concerned person, to impose a monetary penalty between INR 0.35 per kWh and INR 0.45 per kWh of default.

Geothermal Policy

On September 15, 2025, MNRE issued the National Policy on Geothermal Energy ("Policy"). The Policy aims to establish geothermal energy as a mainstream pillar of India's renewable energy architecture, and integrate it as a dependable baseload renewable source supporting India's Net Zero 2070 commitment. It identifies 10 geothermal provinces across the country and promotes applications ranging from electricity generation to direct-use heating, cooling, aquaculture, and industrial processes.

Relevantly, the Policy promotes joint venture and public-private partnership models, particularly with oil, gas and mineral sector entities, including repurposing of existing infrastructure. Further, sets out financial, fiscal and regulatory support measures, including concessional loans, viability gap funding ("VGF"), tax incentives, and renewable energy equivalent treatment under transmission, open-access and carbon-credit regimes. MNRE is designated as the nodal agency, supported by the Geological Survey of India (GSI), Directorate General of Hydrocarbons (DGH), and State Renewable Energy Departments, to develop a geothermal data repository, pilot projects, and centres of excellence for research and development.

Waste-to-Energy Programme

On September 19, 2025, MNRE issued an office memorandum clarifying performance inspection requirements for projects under the Waste-to-Energy Programme, a component of Phase I of the National Bioenergy Programme. Under the revised framework, BioCNG plants are required to undergo performance inspections covering 3 consecutive months of operation, during which they are required to operate continuously for 24 hours at a minimum of 80% of the rated or central financial assistance eligible capacity, whichever is lower.

RCO Compliance

On September 27, 2025, MoP notified the revised renewable consumption obligation ("RCO") under the Energy Conservation Act, 2001, superseding its earlier notification dated October 20, 2023. The new framework establishes a minimum share of renewable electricity consumption out of the total electricity consumed during a financial year for all designated consumers, including distribution licensees, open access consumers, and captive users, with targets extending up to financial year 2029-30.

Some of the key features of this notification are:

• the notification prescribes progressively increasing RCO targets from 29.91% in financial year 2024-25 to 43.33% in financial year 2029-30 covering 4 components, namely, wind, hydro, distributed renewable energy ("DRE"), and other renewable energy;
• designated consumers may fulfil the specified RCO through one or more methods: (i) consumption of renewable electricity, either directly or through an ESS; (ii) purchase or self-generation of renewable energy certificates ("RECs") issued in accordance with relevant CERC regulations; or (iii) payment of a 'buyout price' as determined by the CERC which is a stand-alone compliance mechanism (separate from RECs), enabling consumers to discharge unmet RCO obligations by paying a prescribed amount per MWh of shortfall; and
• with the introduction of this unified framework, the erstwhile state-level renewable purchase obligation ("RPO") regime now stands fully subsumed within the RCO, which operates as the single national renewable consumption obligation.

In furtherance of this framework, on October 22, 2025, CERC through suo motu petition no. 12/SM/2025 issued a proposal to determine the buyout price for unmet RCO shortfall as an alternate compliance mechanism for meeting the RCO, for stakeholder comments. CERC has proposed that the buyout price for financial year 2024–25 be fixed at INR 245/MWh, representing a 5% premium over the weighted average REC price of INR 232.84/MWh recorded during financial year 2024–25. For subsequent years, the buyout price would be set at 105% of the weighted average REC price of the preceding financial year, to be notified annually by the National Load Despatch Centre by April 30.

Further, CERC has clarified in the statement of reasons accompanying the proposal that the buyout option is intended solely as a last-resort compliance mechanism, to be used only when direct renewable consumption or REC purchase is not feasible.

VPPA Guidelines

On December 24, 2025, CERC issued the guidelines for virtual power purchase agreement ("VPPAs") ("VPPA Guidelines"), establishing a regulatory framework for VPPAs as non-tradable and non-transferable specific delivery over-the-counter contracts.

Relevantly the VPPA Guidelines would come into effect from a date to be separately notified by CERC. Further, a VPPA is required to have a duration of at least 1 year. It is structured strictly as a bilateral arrangement between the contracting parties i.e., the renewable energy generating station and the consumer under the Electricity Act/ designated consumer under the Energy Conservation Act, 2001. And, for the entire term of the VPPA, the contracting parties are required to bilaterally settle the difference between the mutually agreed VPPA strike price and the discovered market settlement price at which the electricity is sold.

REEIMS

On October 10, 2025, the Ministry of Commerce and Industry, Department of Commerce issued a notification mandating prior registration on the Renewable Energy Equipment Import Monitoring System ("REEIMS") for imports of specific solar and wind energy components. This registration needs to be completed prior to the import of the specified equipment. This measure, introduced under the Foreign Trade (Development & Regulation) Act, 1992 and aligned with the Foreign Trade Policy 2023, has come into effect from November 1, 2025. Relevantly, registration is required at least 2 days before air cargo shipments and 5 days before sea or land shipments for consignments entering India by land (i.e., imports through notified land customs stations). Each registration would be valid for 3 months, with no fee applicable, and may cover multiple consignments routed through the same port.

Subsequently, in this regard, on October 24, 2025, MNRE issued an office memorandum setting out the procedure for registration on REEIMS portal, including the steps for importer registration, submission of applications, and generation of import certificates.

Biomass Utilization Policy

On November 7, 2025, MoP issued a comprehensive policy for utilization of biomass & torrefied charcoal made from municipal solid waste ("MSW") for power generation through co-firing in coal-based thermal power plants ("Biomass Utilization Policy"), superseding the earlier biomass co-firing policy dated October 8, 2021 and subsequent modifications dated June 16, 2023. The Biomass Utilization Policy inter alia aims to expand co-firing to include torrefied MSW-based charcoal, address surplus agro-residue and unmanaged MSW, reduce greenhouse-gas emissions, mitigate stubble-burning, and support national waste-management objectives under the Swachh Bharat Mission.

Tariff Guidelines

On November 13, 2025, MoP issued guidelines for tariff based competitive bidding process for procurement of power from grid connected waste-to-energy ("WTE") projects under Section 63 of the Electricity Act ("WTE Guidelines"). The WTE Guidelines inter alia aim to facilitate procurement of electricity generated from MSW through a transparent and standardised competitive bidding route, support cleaner waste management practices, and enable municipal corporations, urban local bodies and State-nominated agencies to undertake fair procurement of WTE power.

GIB Matter

The Supreme Court recently in the Great Indian Bustard ("GIB") matter for most approved all the recommendations of the expert committee (constituted by it). Fortunately, the expert committee sought to conserve the critically endangered GIB while ensuring that India's renewable energy commitments and climate change mitigation efforts are not unduly compromised. The court rejected both extremes - the blanket prohibition approach and the complete exemption approach - in favour of a scientifically grounded, site-specific, and phased mitigation strategy.

In brief, the Supreme Court finally deciding on this matter held that:

• the revised priority area for Rajasthan would be 14,013 sq. kms., and for Gujarat would be 740 sq. kms. as recommended by the expert committee;
• restrictions on future renewable energy projects within the revised priority areas of Rajasthan were approved;
• the expert committee's recommendation for immediate undergrounding of 80 km of 33 kV line in Rajasthan was accepted;
• recommendations pertaining to mitigation of 33 kV lines in the revised priority area of Rajasthan were accepted;
• recommendations regarding rerouting of certain specific existing lines of 66kV and above in the revised priority area were accepted;
• all lines of 11 kV and below will be mitigated using insulated cable in horizontal configuration or insulated cables with bunching;
• in case of lines starting from different renewable energy plants but terminating at a common renewable energy pooling station, routes may be optimised to share maximum common stretch to the extent possible;
• the competent authority would engage with the issue of bird flight diverters and take appropriate action based on scientific analysis for deployment; and
• the competent authority would ensure undergrounding of 250 km of critical power lines identified by the Wildlife Institute of India in Rajasthan in a time-bound manner not exceeding 2 years.

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