Originally introduced to regulate the quality of solar photovoltaic modules in large-scale solar projects, the ALMM Order requires manufacturers to be listed on an approved list maintained by MNRE. However, this order raised concerns among stakeholders in the renewable energy sector, especially regarding its applicability to projects that had already received approvals.

The memorandum specifically stated that the exemption applies to projects where the first application for critical permissions—such as in-principle approval, no objection certificate (NOC), government order, or any other relevant approvals—was made before the October 1, 2022 deadline. These approvals must have been sought from entities such as distribution licensees, state transmission utilities (STUs), state load dispatch centres (SLDCs), or other pertinent state and central agencies, in accordance with the respective state or Union Territory policies or electricity regulatory commission rules.

This clarification aimed to alleviate concerns from developers and stakeholders involved in open access and net-metering projects, as several projects initiated before the 2022 amendments were uncertain about the applicability of the updated ALMM regulations. With this clarification, MNRE confirmed that such projects would not be subject to the ALMM listing requirement, provided the necessary permissions were obtained before the specified cut-off date.

An energy expert remarked that this move by MNRE provided much-needed clarity and relief to on-going projects that were in an uncertain regulatory environment due to the changes introduced in 2022. The clarification also applied to projects with existing applications for open access or net-metering in line with the rules of the Central Electricity Regulatory Commission (CERC) or the respective State Electricity Regulatory Commissions (SERCs). This is expected to benefit a range of renewable energy developers, including those involved in large-scale solar, wind, and other renewable energy projects.