How ALMM List-II Is Changing Solar Procurement for C&I Projects

Commercial and industrial buyers who once shopped for solar equipment mainly on price and delivery timelines now have an additional filter to apply early: ALMM eligibility. The Approved List of Models and Manufacturers has become an important procurement consideration for projects covered by the ALMM framework, particularly where government support, net metering, or open access eligibility is involved. For businesses evaluating industrial solar power plants in Chennai, understanding what the framework covers and where it applies is now part of comparing module warranties and inverter brands, not separate from it.

What the ALMM Framework Actually Covers

ALMM began as a mechanism to track which solar module models and manufacturers meet quality and eligibility standards for specified categories of projects. The framework now covers both solar PV modules, under List-I, and, through List-II, solar PV cells, while its applicability extends to specified government, government-assisted, open access, and net-metering projects. MNRE's own guidance states that List-I eligibility applies to Government Projects, Government-assisted Projects, Government Schemes and Programmes, Open Access projects, and Net-Metering projects, so the framework is not a blanket requirement for every solar installation regardless of category.

From Modules to Cells: The List-II Expansion

List-I applies to finished solar PV modules. List-II extends a comparable requirement one step further back in the supply chain, to the solar PV cells used inside those modules. MNRE issued the first List-II on July 31, 2025, and has revised it repeatedly since. For projects to which the List-II requirement applies, a domestically manufactured module may still be non-compliant if the cells used in it do not meet the applicable List-II requirements. This closes a gap that earlier allowed assembly to happen domestically while the underlying cell technology remained largely imported.

Timeline of the Recent Changes

List-II for solar PV cells took effect from June 1, 2026, for the projects to which it applies. MNRE subsequently clarified, in a notice issued on May 25, 2026, that there would be no blanket extension of the requirement, while providing protection for certain investments already made. In July 2026, the ministry introduced a limited window through December 31, 2026, for the commissioning of specified net-metering and open-access renewable-energy projects. Projects outside this limited commissioning window remain subject to the applicable List-II requirements, along with any project-specific exemptions or clarifications MNRE issues from time to time.

MNRE has also been developing the ALMM framework further upstream in the solar manufacturing chain, including work related to ingots and wafers, with a related amendment recorded in March 2026. Buyers should treat this as a sign of direction rather than a fixed and final rule, and should monitor future MNRE amendments rather than assume the current framework is static.

How This Changes Procurement for C&I Buyers

Private C&I Projects Need to Check Their Applicable Category

A private C&I project is not automatically subject to every ALMM requirement simply because it is commercial or industrial. Applicability depends on the project's category, including whether it falls under net metering, open access, a government-supported scheme, or another category covered by the applicable MNRE rules. Lenders and other project stakeholders may also conduct their own compliance and documentation checks, particularly where project eligibility or regulatory approvals affect the financing structure, but that is a separate matter from the ALMM rules themselves. For C&I buyers, the project's regulatory and commercial structure therefore needs to be established before procurement decisions are finalized.

The Net Metering and Open Access Carve-Out

MNRE's July 2026 notice describes a limited window through December 31, 2026, for commissioning specified net-metering and open-access renewable-energy projects, not a general extension across all categories. A group-captive arrangement and a subsidised rooftop project may have different regulatory treatment, so buyers should confirm the applicable ALMM requirements and the project's exact classification before finalizing equipment procurement, rather than assuming a similar-looking project automatically qualifies for the same relief.

A Practical Procurement Checklist for C&I Projects

Recheck Compliance as Milestones Approach

List revisions happen frequently, as manufacturers and models are added to or removed from the applicable lists. MNRE, for example, issued further List-II revisions in July and August 2026, alongside an updated List-I in August 2026. A module or cell source that was compliant at the quotation stage may not remain so by the time equipment is delivered. For projects with long procurement timelines, it is prudent to recheck the applicable MNRE lists as procurement and commissioning milestones approach, rather than verifying only once at the start.

Documentation to Keep on File

• Written confirmation from the supplier of the applicable list status of modules and cells, with the specific model numbers referenced
• Dated list entries captured at the time of quotation, procurement, and commissioning
• Purchase invoices and delivery records that match the enlisted model numbers exactly
• Valid BIS registration details for the modules supplied

MNRE has issued specific provisions for protecting certain investments already made under the ALMM framework, including an order dated May 25, 2026, concerning List-I. Buyers should retain dated procurement records and verify whether the applicable protection provisions cover their project, rather than assuming automatic grandfathering if a manufacturer is later removed from a list.

Budgeting for Sourcing and Cost Impact

ALMM requirements can affect supplier availability, sourcing options, and procurement costs, particularly around periods when manufacturers or models are being added to or removed from the applicable lists. Combined with the existing customs duty structure on imported modules and cells, this makes early supplier verification a practical part of cost planning for C&I procurement, not just a compliance formality.

Why Local Sourcing and Documentation Matter More Now

For businesses in Tamil Nadu, working with solar installation experts in Chennai can simplify part of this compliance burden. A team with close visibility into its supply chain is better placed to provide the documentation and traceability that may be required during regulatory or financing due diligence, rather than leaving a buyer to chase paperwork from a distant supplier after equipment has already shipped. This is especially relevant for facilities considering

commercial solar solutions for Chennai businesses, where financing timelines and net metering approvals depend directly on the paperwork assembled during procurement, not after.

What C&I Decision Makers Should Do Next

MNRE has continued to expand and clarify the ALMM framework through repeated amendments, including work extending further upstream in the solar manufacturing chain. Businesses planning a rooftop, captive, or open-access solar project over the next two to three years should treat category verification and list-status checks as a standard part of vendor evaluation, not an afterthought handled during commissioning. Confirming a supplier's documentation practices and current list status before signing a contract helps avoid the delays many developers faced around the June 2026 deadline.

Frequently Asked Questions

Is ALMM compliance mandatory for private C&I solar projects?

ALMM applicability depends on the project's category and the applicable MNRE requirements. MNRE specifically includes Government Projects, Government-assisted Projects, Government Schemes and Programmes, Open Access projects, and Net-Metering projects within the List-I eligibility framework. Private C&I projects should verify their specific regulatory category rather than assuming ALMM applies, or does not apply, by default.

What is the difference between List-I and List-II?

List-I covers finished solar PV modules. List-II, first issued in July 2025 and revised repeatedly since, covers solar PV cells. The List-II requirement for applicable projects took effect from June 1, 2026, extending list-based eligibility one step further back in the manufacturing chain.

Does the December 2026 window apply to all C&I projects?

No. No blanket extension was granted. MNRE provided a limited window through December 31, 2026, for commissioning specified net-metering and open-access renewable-energy projects. Other projects remain subject to the applicable List-II requirements and any subsequent MNRE clarifications.

What happens if a manufacturer is removed from the list after equipment is purchased?

MNRE has issued provisions for protecting certain investments already made under the ALMM framework. Whether a specific project qualifies depends on the applicable notification and the project's documented procurement status, so dated invoices and list records should be retained and checked against the relevant MNRE order.

How can a business confirm its solar equipment is compliant?

Cross-reference the exact model number, not just the brand name, against the current applicable MNRE list at the time of quotation, procurement, and commissioning, since both List-I and List-II are updated regularly. Also confirm that the module's BIS registration is current, since list status alone does not guarantee compliance if the BIS certificate has lapsed.

Plan Your Next Project With Compliance Built In

The ALMM framework will likely keep evolving, and the businesses that stay ahead of it are the ones that build category checks and list verification into procurement from day one, rather than treating them as a last-minute step. Whether you are evaluating a rooftop system, a captive power arrangement, or a larger industrial installation, working with well-documented, currently listed equipment from the outset saves time at every later approval stage. Contact Us to work through your project's applicable ALMM requirements with a team that manages sourcing, documentation, and commissioning together.