- Grandfathering usually keys off the bid/tender date, not the commissioning date.
- A common cut-off cited is 31 Aug 2025 — verify the exact wording in the MNRE order.
- The 1 Jun 2026 List-II date is litigated — confirm if it was deferred.
- Gather the bid doc, award letter, PO and commissioning certificate as proof.
- If not grandfathered, check the cell source against List-II or seek relief.
You finished the job a few days late, and now the ALMM List-II cell mandate has kicked in. The panic question is simple: does the bid date protect this project, or is it now non-compliant? The answer almost always turns on dates and the exact wording of the MNRE order.
The short answer
Whether a project commissioned after 1 June 2026 is grandfathered usually depends on its bid or tender date, not its commissioning date. Many MNRE orders protect projects that were bid or awarded before a stated cut-off, even if they energise later.
But every word here is point-in-time. The 1 June 2026 List-II trigger faced deferment requests and court proceedings, including at the Karnataka High Court. The grandfathering cut-off (a 31 August 2025 bid date is commonly cited) and its exact wording are set by MNRE and can change. As of 20 June 2026, confirm both against the latest MNRE order before you decide anything.
What grandfathering means
Grandfathering means a project locked in under the old rule is allowed to finish under that rule, even though a new mandate has started. It is a fairness mechanism: a project bid before the new rule existed should not be punished for a change it could not plan for.
In ALMM List-II, grandfathering usually keys off the bid or tender date. A project bid before the cut-off can often complete under the pre-List-II rule. The point of this guide is to help you check whether your project sits on the right side of that line — and to remind you that the line itself is set by MNRE and can move.
Which date counts
The date that usually decides grandfathering is the bid or tender date, not the day you commissioned. A project bid before the stated cut-off can often finish under the old rule even if it energises after the trigger.
Bid date vs commissioning date
Think of two dates. The bid date tends to decide which rule set applies to the project. The commissioning date decides when the mandate would otherwise bite. If your bid date is before the cut-off, the late commissioning may not matter. If your bid date is after it, the late commissioning can put you under the new rule.
Confirm the date your order uses
Do not assume which date your order keys off. Some clauses use the bid date, some the letter of award, some the PPA date. Read the grandfathering clause in the current MNRE List-II order and match it to your project's paperwork. If the wording is unclear, ask the DISCOM or a compliance adviser.
Grandfathered or not? A decision table
Use this table to find your likely position. It is a starting point, not a ruling — the final answer is in the MNRE order wording.
Dates and outcomes are illustrative and litigated — verify the cut-off, the trigger date and the grandfathering wording against the current MNRE order.
Evidence to gather now
Whatever your position, the proof is the same: dated documents that show when the project was locked in and when it energised. Pull these together before you talk to anyone.
- Bid or tender document — dated, showing the submission or award timing.
- Letter of award / work order — confirms when the project was committed.
- Purchase order for modules — shows what was ordered and when.
- Commissioning certificate — the official energisation date.
- DCR certificates / ALMM proof — the compliance record for the modules used.
Match this evidence against the grandfathering clause in the current MNRE order. The exact documents a reviewer accepts can vary, so confirm the requirement rather than assume.
If you are not grandfathered
If the dates put you under the new rule, the project must meet the List-II cell mandate — the cells in your modules need to come from an enlisted Indian maker. Your options narrow, but you still have moves.
Check the cell source first
You may already be compliant without knowing it. Check whether the cells in your installed modules come from a List-II maker. If they do, you meet the mandate and the late commissioning is moot.
Seek relief or replacement
If the cells are not compliant, look at relief filings, exemption windows, or — in the worst case — module replacement on the affected part. A delisting or mid-project change has its own playbook in module delisted mid-project. Take advice from a compliance adviser before you commit to a costly fix.
Avoiding this on the next job
This whole scramble comes from a date that crept up. Stop it happening again by tracking the mandate dates against every live project from the start.
Keep a live view of the trigger dates and your project milestones side by side, so a slipping commissioning date raises a flag weeks early, not on the day. Our deadlines calendar lists the dates to watch, and the List-II cell mandate guide explains the rule you are racing.
How SuryaHub helps you stay ahead of the cut-off
The fix for date risk is a system that watches the dates for you. SuryaHub records the bid date, award date, purchase order and commissioning date on each project in its government workflows, so you can show when a job was locked in against a mandate cut-off, and a slipping schedule raises a flag early. SuryaHub is pre-revenue; the only real pilots are Suryantra Energy and RGESPL, and every date above should be verified against the current MNRE order.
Never miss a mandate cut-off
See how SuryaHub tracks bid and commissioning dates on every project.
Related guides
Frequently asked questions
Is my project grandfathered if it commissioned after June 1, 2026?+
Whether a project commissioned after 1 June 2026 is grandfathered usually depends on its bid or tender date, not its commissioning date. Many orders protect projects bid before a stated cut-off. The wording is point-in-time and litigated, so confirm the exact grandfathering clause in the current MNRE List-II order before you rely on it.
What is grandfathering in ALMM List-II?+
Grandfathering in ALMM List-II means a project locked in under the old rule is allowed to finish under that rule, even though a new mandate has started. It usually keys off the bid or tender date. The exact cut-off and wording are set by MNRE and can change, so verify them against the current order.
Which date decides grandfathering, bid date or commissioning date?+
Grandfathering usually keys off the bid or tender date rather than the commissioning date. A project bid before the stated cut-off can often finish under the old rule even if it commissions later. The commissioning date matters for when the mandate bites. Confirm which date your order uses against the current MNRE notification.
Was the June 1, 2026 ALMM List-II date deferred?+
The 1 June 2026 ALMM List-II date faced deferment requests and court proceedings, so it should not be treated as a settled fact. As of 20 June 2026, confirm whether it was deferred or changed in the latest MNRE order before you decide whether your project is non-compliant.
What evidence proves my project is grandfathered?+
To show a project is grandfathered, keep the dated bid or tender document, the award letter, the purchase order, and the commissioning certificate. These prove when the project was locked in and when it was energised. Match this against the grandfathering clause in the current MNRE order, since the exact evidence required can vary.
How does SuryaHub help with grandfathering checks?+
SuryaHub records the bid date, award date, purchase order and commissioning date on each project, so you can show when a job was locked in against a mandate cut-off. SuryaHub is pre-revenue; the only real pilots are Suryantra Energy and RGESPL, and all dates should be verified against the current MNRE order.
Sources & references
The List-II order, its trigger date and the grandfathering wording come from MNRE and several are litigated. Confirm the current position before you act.
- Ministry of New & Renewable Energy (MNRE) ↗
The ALMM List-II order, its effective date and any grandfathering wording (verify the current order).
- NISE DCR portal ↗
DCR certificate records that support a compliance claim.
- National Portal for PM Surya Ghar ↗
Where DCR and timing matter for subsidy-linked projects.
Written by the SuryaHub team · reviewed against MNRE, NISE & BIS sources · updated 20 June 2026.
Method: Grandfathering logic is drawn from MNRE ALMM List-II policy and re-checked every 30 days. The trigger date and the bid cut-off are litigated and point-in-time — verify against the current MNRE order. SuryaHub is pre-revenue; only Suryantra Energy and RGESPL are real pilots.
Change log: 20 Jun 2026 — first published.