ALMM / DCR Modules for a C&I Solar Plant: When It Matters and When It Doesn't

For a commercial or industrial solar plant, ALMM List-I (modules) applies to net-metered and open-access plants, and List-II (cells) applies to them if the plant is commissioned after 31 December 2026. A private plant genuinely behind the meter, solely for its own use, is outside both lists. DCR is a separate scheme condition. Connection type and commissioning date decide most cases.

Which rule is which?

• ALMM List-I is MNRE's list of approved solar PV module models and manufacturers.
• ALMM List-II is the equivalent list for the solar cells inside those modules.
• DCR, the Domestic Content Requirement, is not an ALMM rule. It sits in the guidelines of individual government schemes. MNRE's memorandum of 4 August 2026 says the ALMM orders have no impact on DCR provisions and do not relax any scheme's use of domestically made modules and cells.

Buyers often hear the three as one. A plant can be inside ALMM and outside DCR, which is the usual case for an unsubsidised factory roof, or it can be inside both when a scheme applies.

Which route triggers which list?

The memorandum construes "net-metering" to include all forms of grid connection and interaction other than behind-the-meter connections. It also states that the List-II exemption needs no application on the portal and holds irrespective of whether the project began before or after 18 July 2026. Projects awarded through bidding follow bid-date cut-offs set out in the memorandum, and rooftop projects on government buildings have their own rows there; neither applies to a private factory plant.

What decides your case?

The connection, as built. A plant described as captive but exporting to the grid, or settled through the DISCOM, is in the net-metering family for this purpose. We will not suggest changing a connection to escape a module rule: export, settlement and the DISCOM's requirements are engineering and commercial choices with their own consequences, and a plant described as behind the meter that is not so exposes you on both counts.

The commissioning date. The exemption is tied to commissioning, meaning the plant is energised and accepted, with the paperwork to show it. A purchase order, an advance or modules delivered to site do not meet it. Build the realistic programme, including DISCOM and inspection steps, before you choose modules; if honest commissioning falls after 31 December 2026, buy cells that are on List-II. Our 2026 commissioning guide sets out the operative text.

When does DCR matter?

Only where a scheme or tender imposes it. Central schemes such as PM Surya Ghar and PM-KUSUM components carry domestic content conditions in their guidelines, and their rules govern which module and cell combination qualifies. A commercial plant with no subsidy and no scheme involvement can use modules that are not DCR. That does not make them unregulated, since ALMM may still apply by route. If you are claiming any benefit, read the scheme's guideline and ask the supplier for the domestic content certificate; our pages on PM Surya Ghar and the DCR glossary entry cover the common cases.

What about bankability and warranty?

ALMM status is an eligibility check, not a quality grade. It says the model or cell maker is on MNRE's list at a point in time. MNRE revises both lists often; at the last review of the ministry's ALMM page, in early October 2026, List-I had been updated on 16 September and List-II had reached its tenth revision on 28 September. A model that is listed on the day you order can matter less than one that is still listed on the day of supply and the day of inspection. For bankability, ask for independent test reports, the manufacturer's financial standing, product and performance warranty terms, and a local entity you can make a claim against. A warranty from a maker with no Indian presence may be hard to enforce. See also our note on ALMM List-II and module bankability.

What should the EPC contract say?

• Module model and make named, with its List-I status on the date of supply, and the cell manufacturer with its List-II status where List-II applies.
• Commissioning defined as the date the DISCOM or authority records, with who bears the risk if it slips past 31 December 2026 and the cells then need to be on List-II.
• Remedy: replacement at the supplier's cost if a model is found non-compliant or is removed from the list before inspection.
• Traceability: invoices, serial numbers and the manufacturer's declaration kept in the commissioning file.
• Scheme documents: a DCR certificate only if a scheme requires one.
• Change control: no change of module model without your written approval.

How do you check a quoted module?

1. Take the exact model number and manufacturer's name from the datasheet, not the brand on the quotation.
2. Look the model up on the current List-I on MNRE's ALMM page, and note the date you looked.
3. Ask the bidder in writing for the cell manufacturer and its factory, and check that maker on List-II if the plant will commission after 31 December 2026.
4. Repeat the check when the modules are dispatched and again before the inspection, since the lists are revised.
5. Save the screenshots, datasheet and supplier declaration in the commissioning file for the DISCOM and for your records.

Compare quotations on that list rather than on rupees per watt. Our guide to evaluating solar EPC proposals shows the other lines to compare, and the ALMM glossary entry gives the short definition.

How Secured Engineers helps

We design C&I solar in-house and file DISCOM net-metering applications in-house, so connection type and commissioning programme are set at the design stage, before modules are chosen. Fire NOC and CEIG work are filed in-house where the site needs them, and solar, electrical and fire work can sit under one contract. We work from offices in Noida (Delhi NCR) and Ludhiana, with 535+ projects across 18+ states and 89.77% repeat clients. Indicatively, the published C&I band is ₹24,000–32,000 per kW excluding GST; module eligibility is one of the lines that moves a quotation inside it.

If you have a quotation or a datasheet in hand, send it and we will tell you which list applies to your connection and what to ask the supplier. Start from our solar EPC page, message us on WhatsApp, call +91 70099 85817, or ask for a free proposal.