Rooftop solar ALMM exemption: what the 31 December 2026 deadline means for a factory or commercial plant

The short answer: a net-metered or open-access rooftop solar plant that is commissioned on or before 31 December 2026 may use solar cells that are not on MNRE's ALMM List-II. From 1 January 2027 it may not. The modules must come from ALMM List-I either way. A private captive plant genuinely behind the meter is outside both lists. That is the whole of MNRE's position in its two memoranda of 18 July and 4 August 2026, and the rest of this page is what it means for a plant you are deciding on now.

What was extended, and what was not

In the ministry's own words there is "no blanket extension in applicability of ALMM List-II for solar power projects" — the 31 December date is "a limited window" for the two categories named. Searches for a general "rooftop solar deadline extension" are looking for something that does not exist.

Why the date is about commissioning

The 4 August clarification settles the question suppliers argue about: the exemption applies "if commissioned by 31.12.2026, else not", "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". The purchase order, the advance, the module delivery and the date on a quotation are all irrelevant to it. The plant has to be energised and accepted as complete, with the evidence to show it.

For a factory rooftop in North India that means counting back from the deadline through DISCOM and CEIG filings, structural work, procurement lead times and the December fog window. A plant whose honest commissioning date is in the first quarter of 2027 is a List-II plant, and its modules should be chosen on that basis now rather than argued about in January.

What to decide before choosing modules

1. How the plant connects. Net-metering family, open access, or genuinely behind the meter — this decides which column you are in. It is an engineering and commercial choice with its own consequences; we do not recommend changing a connection to escape a module rule.
2. Whether a scheme or tender is involved. If so, its DCR terms apply on top, and nothing in the ALMM orders relaxes them.
3. The dated commissioning programme. Not the hoped-for date — the one the filings and the lead times support.
4. The module model's List-I status at supply, and its cell's List-II status if the programme runs past the deadline.

The full reading of both memoranda, including the bidding-date tiers for tendered projects and the residential PM Surya Ghar provision, is in the DCR vs non-DCR and ALMM List-II commissioning guide. For the plant itself, start with industrial rooftop solar EPC or the solar savings report.