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					</table><p>The Rajasthan Electricity Regulatory Commission (<a href="https://rerc.rajasthan.gov.in/" target="_blank" rel="noopener">RERC</a>) has dismissed petitions filed by two textile companies seeking exemption from Renewable Purchase Obligation (RPO) compliance for electricity generated and self-consumed from behind-the-meter captive solar power projects.</p>
<p>The Commission ruled that captive projects with an installed capacity of at least 1 MW remain obligated entities under the RERC (Renewable Purchase Obligation) Regulations, 2023, irrespective of whether the captive generation is renewable or conventional.</p>
<p>However, it clarified that renewable electricity generated and consumed behind the meter will count toward fulfilling the entity&#8217;s RPO, eliminating the need for any additional renewable power procurement to the extent the self-consumption satisfies the prescribed obligation.</p>
<p><strong>Background</strong></p>
<p>The petitioners, Sudiva Spinners, which operates rooftop and ground-mounted captive solar projects with a cumulative capacity of 14.984 MW, and textile manufacturer RSWM, which has captive solar projects of more than 1 MW at each of its six manufacturing units in Rajasthan, approached the Commission seeking clarity on the applicability of RPO to behind-the-meter captive renewable energy generation.</p>
<p>The petitioners argued that RPO was originally conceived when thermal generation dominated the power sector and before widespread deployment of behind-the-meter solar installations.</p>
<p>Since RPO aims to reduce carbon emissions from fossil-fuel generation, they contended that imposing RPO on renewable energy generated and consumed within a consumer&#8217;s premises defeats the objective of promoting clean energy.</p>
<p>They also pointed out that several state regulators, including those in Maharashtra, Gujarat, Karnataka, Tamil Nadu, Haryana, Telangana, and Punjab, exempt renewable energy-based captive power plants from RPO obligations.</p>
<p>The companies submitted that the regulatory ambiguity was affecting their ability to monetize environmental attributes through International Renewable Energy Certificates (I-RECs).</p>
<p>The respondent, Rajasthan Renewable Energy Corporation (RRECL), the state&#8217;s nodal agency for RPO implementation, opposed the petitions, arguing that captive power plants are expressly identified as obligated entities under the regulations.</p>
<p>It argued that electricity generated and consumed from such captive solar installations already qualifies as renewable consumption and contributes toward meeting RPO targets, but does not exempt the entity from the obligation itself.</p>
<p>RRECL also maintained that renewable energy used for RPO compliance cannot simultaneously be claimed for REC or I-REC issuance, as doing so would amount to double counting of environmental attributes.</p>
<p><strong>Commission&#8217;s Analysis</strong></p>
<p>The Commission observed that the RPO Regulations, 2023, unequivocally apply to distribution licensees, open access consumers, and captive power plants with an installed capacity of 1 MW and above, without distinguishing between renewable and conventional captive generation. Since both petitioners operate captive solar plants that exceed the prescribed threshold, the Commission said they clearly qualify as obligated entities under the regulations.</p>
<p>It noted that the legality of imposing RPO on captive power plants had already been upheld by the Rajasthan High Court in 2012, with the Supreme Court affirming the judgment in 2015.</p>
<p>It said the RPO Regulations, 2023, form part of the same statutory framework and continue to derive authority from the Electricity Act, 2003.</p>
<p>The Commission rejected the petitioners&#8217; contention that RPO penalizes renewable captive generation, stating that the obligation is consumption-based rather than procurement-based.</p>
<p>It ruled that electricity generated and consumed from behind-the-meter captive solar projects itself constitutes renewable energy consumption and therefore serves as the means by which the obligated entity fulfills its RPO.</p>
<p>According to the Commission, no additional procurement of renewable energy is required, provided that self-consumed captive solar generation meets the prescribed RPO target.</p>
<p>Addressing the petitioners&#8217; concerns regarding carbon credits and I-RECs, the Commission reiterated the established principle of non-double counting. It held that once the environmental attributes of renewable electricity are transferred through RECs, I-RECs, or similar environmental certificates, the same units cannot be counted toward RPO compliance.</p>
<p>Conversely, renewable electricity used to demonstrate RPO compliance cannot simultaneously generate tradable environmental attributes.</p>
<p>Finding that no genuine implementation difficulty existed, the Commission dismissed the petitions.</p>
<p>It held that captive users operating captive power plants of at least 1 MW remain obligated entities under the RPO Regulations. At the same time, renewable electricity generated and self-consumed behind the meter shall count toward discharging their own RPO, without requiring additional renewable energy procurement, to the extent the specified obligation is met.</p>
<p>In May 2026, RERC <a href="https://www.mercomindia.com/rajasthan-introduces-new-renewable-energy-purchase-compliance-rules" target="_blank" rel="noopener">introduced</a> new renewable energy compliance requirements and distributed renewable energy targets and aligned state rules with the central government’s RCO framework.</p>
<p>Subscribe to Mercom’s real-time <a href="https://mercomindia.com/product/mercoms-renewable-energy-regulatory-updates/" target="_blank" rel="noopener">Regulatory Updates </a>to ensure you don’t miss any critical updates from the renewable industry.</p>


Rajasthan Regulator Rejects Plea to Exempt Captive Solar Projects from RPO


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					</table><p>The <a href="https://home.maharashtra.gov.in/en/" target="_blank" rel="noopener">Government of Maharashtra</a> has constituted a committee to examine the applicability of electricity duty on rooftop solar consumers, behind-the-meter systems, and grid support charges, amid rising adoption of distributed renewable energy in the state.</p>
<p>The decision comes as changing electricity consumption patterns driven by rooftop solar installations and captive generation prompt a reassessment of the existing duty framework under the Maharashtra Electricity Duty Act, 2016.</p>
<p>Electricity duty is currently levied on power consumption across all consumer categories and includes fixed charges, energy charges, fuel adjustment charges, and reliability charges. However, the growing adoption of rooftop solar and BTM systems has altered traditional consumption patterns, raising questions about how duty should be applied to self-generated and self-consumed electricity.</p>
<p>The development follows an order by the Maharashtra Electricity Regulatory Commission (MERC), which allowed the levy of grid support charges on rooftop solar systems with capacities above 10 kW. The state government has now initiated a policy-level review to determine whether electricity duty should also be applied on such charges.</p>
<p>The committee has been tasked with evaluating the applicability of the electricity duty across several dimensions. This includes examining whether duty should be levied on electricity consumed under self-consumption and net metering arrangements, as well as on electricity generated and consumed by rooftop solar users.</p>
<p>It will also assess the applicability of the electricity duty to grid support charges for rooftop solar consumers and the feasibility of transitioning from a fixed-rate to a percentage-based mechanism.</p>
<p>For behind-the-meter systems, including captive generation and storage-based setups, the committee will evaluate whether an electricity duty should be imposed on on-site electricity generation and consumption.</p>
<p>In addition to technical applicability, the committee will assess the broader financial and policy implications of any proposed changes. This includes analyzing the potential impact on state government revenue and the financial position of distribution companies.</p>
<p>The panel will also recommend possible exemptions and incentives for specific consumer categories while ensuring a balance between promoting renewable energy adoption and safeguarding revenue streams.</p>
<p>The committee has been given 10 days to submit its report.</p>
<p>The Maharashtra Electricity Regulatory Commission recently <a href="https://www.mercomindia.com/maharashtra-tariff-for-surplus-rooftop-solar-power-in-fy-2027/?utm_source=chatgpt.com" target="_blank" rel="noopener">approved</a> a generic tariff of ₹2.82 (~$0.030)/kWh for surplus rooftop solar power.</p>
<p>Subscribe to Mercom’s real-time <a href="https://mercomindia.com/product/mercoms-renewable-energy-regulatory-updates/" target="_blank" rel="noopener">Regulatory Updates</a> to ensure you don’t miss any critical updates from the renewable industry.</p>


Maharashtra Forms Panel to Review Electricity Duty on Rooftop Solar


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					</table><p>The Ministry of New and Renewable Energy (<a href="https://mnre.gov.in/" target="_blank" rel="noopener">MNRE</a>) has clarified that behind-the-meter projects for captive consumption by government entities or public sector enterprises must use solar modules from the Approved List of Models and Manufacturers (ALMM).</p>
<p>However, these projects are exempt from using ALMM-compliant cells if they were commissioned before June 1, 2026. Projects commissioned after this deadline must use ALMM-listed modules and cells.</p>
<p>This clarification follows a query from stakeholders who sought to confirm whether compliance with the ALMM list for solar cells is not required for behind-the-meter connections commissioned before June 1, 2026, and executed under the renewable energy service company or capital expenditure modes for self-consumption purposes.</p>
<p>In 2022, MNRE exempted behind-the-meter solar projects solely used for captive consumption by a consumer or group of consumers.</p>
<p>The Ministry clarified that this exemption does not apply to behind-the-meter connections for captive consumption by government entities or public sector enterprises, as government projects have been covered under ALMM from the beginning.</p>
<p>As of June this year, ALMM approved module capacity <a href="https://www.mercomindia.com/almm-authorized-solar-module-manufacturing-capacity-rises-by-2-98-gw" target="_blank" rel="noopener">stood</a> at 90.95 GW. The Ministry updated the ALMM by adding 2,988 MW of solar module manufacturing capacity. The total number of module manufacturers has now increased to 105.</p>
<p>Reliance Industries is the latest addition to the ALMM list, with a capacity of 1,716 MW. Avaada Electro increased its capacity by adding 1,272 MW.</p>
<p>In May, MNRE <a href="https://www.mercomindia.com/mnre-issues-clarifications-on-enlisting-solar-cells-in-almm" target="_blank" rel="noopener">issued</a> clarifications on solar cells in the ALMM. It clarified that it would treat potential induced degradation (PID) and non-PID cells as different products or families and list them separately.</p>
<p>In March, MNRE <a href="https://www.mercomindia.com/mnre-clarifies-net-billing-and-metering-provisions-under-almm" target="_blank" rel="noopener">clarified</a> that net billing, virtual, and group net metering will also be treated on par with net metering provisions under ALMM List-II.</p>
<p>Last year, the Ministry clarified that the List II <a href="https://www.mercomindia.com/list-ii-for-solar-cells-into-force-from-june-2026" target="_blank" rel="noopener">applies </a>to solar cells, which will be brought under the ambit of ALMM from June 2026. The inclusion of solar cells in ALMM aims to increase the  domestic production capacity of solar cells.</p>


MNRE Issues Clarifications on ALMM Mandate for Behind-the-Meter Projects


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					</table><p>The Maharashtra Electricity Regulatory Commission (<a href="https://merc.gov.in/" target="_blank" rel="noopener">MERC</a>) has increased the net metering cap for rooftop solar power projects to either 5 MW or the consumer’s contract demand/ sanction load, whichever is lower. Net metering in the state was earlier capped at less than 1 MW.</p>
<p>The increase in the net metering cap comes across as an effort to encourage the adoption of commercial and industrial rooftop installations.</p>
<p>The Commission has also allowed consumers to opt for group net metering, net billing, or behind-the-meter connection.</p>
<p>The amendments are a part of the latest Maharashtra Electricity Regulatory Commission (Grid Interactive Rooftop Renewable Energy Generating Systems) (First Amendment) Regulations, 2023.</p>
<p>According to the proposed amendments, an eligible consumer is an electricity consumer within the distribution company’s (DISCOM) service area who uses or intends to use a renewable energy generation system. The system can be situated on its rooftop or another support structure on its premises. This definition encompasses consumers who collectively utilize a shared load, such as those within a housing society.</p>
<p><strong>Grid Support Charges</strong></p>
<p>The Commission has clarified that grid support charges will not be imposed until the total installed rooftop capacity in the state reaches 5 GW. However,  DISCOMs can approach the Commission to seek approval or clarification regarding charges associated with energy banking.</p>
<p><strong>Gross Metering</strong></p>
<p>Under the amended regulation, the Commission has allowed gross metering. According to the amendment, gross metering involves setting up a renewable energy generation system to sell all the electricity generated to DISCOM through a power purchase agreement.</p>
<p>However, if the renewable energy generation system is linked to the consumer’s side of the meter, the existing meter must be replaced with a net meter.</p>
<p>Under the gross metering arrangement, all the electricity recorded by the generation meter will qualify for meeting the DISCOM&#8217;s renewable purchase obligations (RPO).</p>
<p><strong>Group Net Metering</strong></p>
<p>The Commission has introduced group net metering through the new amendment. It involves surplus units injected into the grid from a rooftop system or any other mounting structure in the consumer’s premises that will be adjusted against the energy consumed in the monthly bill of service connections based on a priority list and sharing ratio.</p>
<p>The adjustment priority begins after accounting for units at the service connection where the rooftop system is located.</p>
<p>The consumer can revise the priority list and share ratio for surplus energy adjustment against other electricity connections at the start of every financial year, with a two-month advance notice.</p>
<p>The electricity consumption in any time block will first be compensated with the electricity generation in similar time blocks in the same billing cycle of the consumer where the rooftop system is located.</p>
<p>Surplus units are then adjusted against the energy consumed in other service connections based on the priority list and ratios provided by the consumer. If the surplus generation/ energy credits occurred during the off-peak time block for the time of day (TOD) consumers and the normal time block for non-TOD consumers. If, during a billing period, exported units exceed imported units, the surplus units are carried forward as energy credits to the next billing period.</p>
<p>The unadjusted net credited units of electricity at the end of each financial year will be purchased by DISCOM at the generic tariff approved by the Commission for that year within the first month of the following year. However, at the beginning of each settlement period, the injected electricity carried forward will be reset to zero.</p>
<p>If the accumulated credit amount keeps increasing for three consecutive financial years, 50% of that amount will be paid in cash to the consumer within 60 days at the end of the third financial year. The remaining 50% will be credited to the second electricity bill after the end of the third financial year.</p>
<p>If there is a delay in payment or crediting beyond 60 days, the DISCOM must pay simple interest on the outstanding amount. The interest rate is determined by the prevailing one-year Marginal Cost of Lending Rate of the State Bank of India plus 150 basis points to the eligible consumer.</p>
<p>Wheeling charges and losses for surplus energy wheeling to other premises under group net metering are exempted until the installed rooftop capacity in Maharashtra reaches 5 GW.</p>
<p><strong>Net Billing Arrangement</strong></p>
<p>The Maharashtra Commission has amended the net billing arrangement. In this setup, surplus energy injected into the grid by a rooftop system is purchased by the DISCOM. The DISCOM then raises the bills on the consumer for his consumption from the grid at the approved grid tariff after giving credit for energy injected into the grid at a pre-determined tariff.</p>
<p>The accounting of electricity exported and imported by the consumer will become effective from the date of connectivity of the rooftop system with the distribution network. According to the regular metering cycle, the DISCOM must undertake a meter reading of both the renewable energy generation meter and the net meter for all eligible consumers.</p>
<p>For each billing period, the DISCOM must furnish the eligible consumer with specific information on the electricity bill. This includes details of the renewable energy generated, with an account of opening and closing balances recorded by the renewable energy generation meter. The bill must specify the quantity of electricity units consumed by the consumer, including opening and closing balances.</p>
<p>Information regarding the amount of energy injected into and drawn from the grid by prosumers is also to be included. The bill should detail the renewable energy generation units the DISCOM utilizes for RPO compliance.</p>
<p>Last December, MERC <a href="https://www.mercomindia.com/maharashtra-regulator-rejects-petition-seeking-changes-to-open-access-policy" target="_blank" rel="noopener">highlighted</a> certain crucial amendments required to rooftop solar and green energy open access regulations. The changes included leasing rooftops or premises to install a solar system and use the power through open access.</p>
<p>Subscribe to Mercom’s real-time <a href="https://mercomindia.com/product/mercoms-renewable-energy-regulatory-updates/" target="_blank" rel="noopener">Regulatory Updates </a>to ensure you don’t miss any critical updates from the renewable industry.</p>


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