Non-DCR solar panels and ALMM List-II: the 2026 commissioning guide

If you have asked three suppliers about solar modules this year you have probably been told three different things about "DCR", "ALMM" and a deadline. Some of what you were told is right for a different kind of project. This page sets out what the two governing MNRE orders actually say, which projects each rule reaches, and the single question that decides most of it: when will the plant commission?

Check your project's applicable rules and achievable commissioning programme before you choose modules.

Three rules, not one

"Non-DCR panels" therefore means modules that do not meet a scheme's domestic-content condition. For a commercial plant with no subsidy and no tender, DCR is simply not in play. What is in play is ALMM — and which list, and from when, depends on how the plant connects and when it commissions.

What the two orders say

18 July 2026 — O.M. No. 283/53/2026-GRID SOLAR

MNRE's earlier position was that net-metering and open-access RE projects commissioned on or after 1 June 2026 must use List-I modules and List-II cells, with no blanket extension of List-II. The 18 July order supersedes the May and June 2026 orders on that point. In the ministry's own words, while there will be no blanket extension in applicability of ALMM List-II for solar power projects, however, a limited window is being provided for Net-metering projects and Open Access RE power projects, whereby such projects can now commission with exemption of ALMM List-II (for solar PV cells), till 31st December 2026. Projects commissioned after that date will be required to comply with the ALMM List-II provisions.

4 August 2026 — O.M. No. 283/54/2026-GRID SOLAR (clarification)

Issued in response to requests for clarification, and it is the document to read if your project is anything other than a straightforward private rooftop. Its operative points:

• Net-metering and open access, para (b). Exempt from List-II if commissioned by 31.12.2026, else not. The exemption is only for ALMM List-II (for solar PV cells), and compliance to ALMM List-I (for solar PV modules) still needs to be followed. It applies irrespective of whether the project is initiated pre or post 18.07.2026, and without any need/pre-requisite of any application on the portal.
• What "net-metering" covers. The order construes it to include Gross Metering, Net Billing, Net Feed In, Virtual Net Metering, Group Net Metering, etc. but excluding Behind-The-Meter connections.
• Behind-the-meter, para (e). List-I and List-II shall not apply to behind-the-meter solar power plants solely used for captive consumption by a consumer or group of consumers, other than Government entities or Public Sector Enterprises. Government and PSU behind-the-meter plants must use List-I modules, and List-II cells too if commissioned after 31 December 2026.
• Projects awarded through bidding, paras (a) and (c). Governed by the last date of bid submission against cut-offs of 9 December 2024, 28 July 2025 and 31 August 2025, with tender conditions prevailing in the middle band. These tiers are for tendered and government-building projects; they do not transfer to a private factory's plant.
• Residential, para (b). Net-metering consumers who opt to give up the PM Surya Ghar subsidy are exempt from List-II until the scheme period ends on 31 March 2027, subject to applying through the PMSG National Portal; List-I still applies. This is a residential provision and says nothing about commercial plants.
• DCR, para (f). The Domestic Content Requirement (DCR) provisions in respective Schemes are governed by the Scheme Guidelines … and not by the orders / O.M.s on ALMM; the ALMM orders do not relax DCR anywhere.

The trigger is commissioning

Everything in the 31 December 2026 window turns on the commissioning date of the plant — the date it is energised and accepted as complete, with the documentary evidence to show it. Not the purchase order. Not the advance. Not a booking confirmation from a supplier. A module shipment sitting in a warehouse on 31 December is not a commissioned plant, and nothing in either order treats it as one.

That is why the realistic programme matters more than the quoted one. A 500 kW rooftop on a working factory in North India runs through structural checks, DISCOM and CEIG filings, procurement lead times and the winter fog window before it is energised. If the honest commissioning date for your project is in the first quarter of 2027, the List-II exemption is not available to it, and the module decision should be made on that basis from the start rather than discovered at inspection.

What is outside both lists

A private business running a solar plant solely for its own consumption, behind its own meter, with no interaction with the grid, is outside ALMM List-I and List-II under para (e). That is a statement about the connection, not about the owner's intentions: a plant that is described as captive but is in fact net-metered, feeding in, or settled through the DISCOM is a net-metering project for this purpose and is reached by both lists on the dates above.

We will not suggest reconfiguring a connection to move a plant from one column to the other. Whether to export surplus, how it is settled, what the DISCOM requires and what the plant is worth to you are engineering and commercial questions with consequences of their own. Choose the connection for the right reasons; then apply the rules that follow from it.

What we check before advising on a 2026 project

1. Connection arrangement, as it will actually be built — net-metering family, open access, or genuinely behind the meter — from the application, not the description.
2. Scheme, subsidy or tender involvement, and the DCR terms of that scheme, read from its own guidelines.
3. The realistic commissioning date against 31 December 2026, built from the actual programme including approvals and the season.
4. The exact module model quoted, its List-I status at the time of supply, and — where List-II will apply — the cell eligibility, from the current lists rather than a supplier's assurance. List-I was last updated on 16 September 2026 and List-II is on its tenth revision as of 28 September 2026; both move.
5. Utility acceptance — whether your DISCOM's own process asks for anything beyond MNRE's position.
6. A check for any superseding MNRE order issued after the ones cited here.

Module pricing follows from those answers. Enlisted-cell modules and other modules are different products at different prices; the difference on any given day is a matter of scope-matched supplier quotations, not a figure to publish, and a price difference today is not a forecast of one tomorrow.

After the window

This page will not be taken down on 1 January 2027. The status block at the top switches to historical wording automatically on that date in Indian Standard Time, and the body will be revised against MNRE's position at the time. The URL stays stable so that anything linking here keeps working.