- ALMM often applies to open access and wheeling — the exact rule depends on the current MNRE order (verify).
- DCR is usually not required for open access unless a scheme adds it.
- An open-access / wheeling exemption window may apply, reported to around 1 June 2028 (verify).
- Open access and net metering carry different rules — check ALMM and exemptions for each route.
- Group captive has its own ownership and consumption tests (≥26% reported — verify).
Open access is where the bigger C&I solar projects live, and the compliance rules there are more flexible than subsidy work — but "more flexible" is not "no rules". ALMM frequently still applies, and the open-access exemption window is one of the most misquoted points in the market. Here is the honest version.
The short answer
ALMM often applies to open-access and wheeling solar, but the exact requirement depends on the current MNRE applicability order and the segment. DCR is usually not required, because open access is a private commercial arrangement rather than a domestic-content scheme. An exemption window may apply to certain projects. Verify every point against the latest MNRE order and the relevant SERC.
What open access and wheeling are
Open access lets a large consumer buy power from a generator other than the local DISCOM, using the grid to carry it. Wheeling is the act of moving that power across the network for a charge. Together they let a factory or commercial client source solar from a project that may sit far from the load. These are governed by State Electricity Regulatory Commission (SERC) regulations plus central rules.
This is a different world from a homeowner with a rooftop. The loads are big, the contracts are commercial, and the regulator is the SERC, not just the DISCOM. That changes how ALMM and DCR land — which is the whole point of this guide.
Does ALMM apply to open access?
ALMM often applies to open-access and wheeling solar, but the exact requirement depends on the current MNRE applicability order and the segment. Open access is more flexible than subsidy work, yet many projects still need an ALMM-enlisted model. Verify whether ALMM applies to your open-access or wheeling project under the latest MNRE order before you source modules.
The trap is assuming "private project means no ALMM". That is not safe. ALMM applicability has widened over time, and an open-access project can still be caught. Check the live order for your segment rather than rely on what was true a year ago. Our applicability guide maps where the list bites.
Is DCR required for open access?
DCR is usually not required for open-access and wheeling solar, because these are private commercial arrangements rather than domestic-content schemes. A DCR module becomes necessary only if a specific scheme or tender layered on top demands it. Verify the current rule, because applicability changes and a particular state or scheme may add a requirement you did not expect.
So for a typical open-access deal, you are not forced onto DCR modules — which keeps module choice and cost more open. But always read the contract and any scheme overlay. A state incentive bolted onto the project could quietly pull DCR back in.
The wafer / cell exemption window
The open-access wafer exemption refers to a window in which certain open-access and net-metering projects may be exempt from a deeper domestic-content requirement, reported to run to around 1 June 2028. The exact scope and end date are set by MNRE and can change. Confirm the current exemption window against the latest MNRE order before you rely on it for sourcing.
This exemption is the source of a lot of confusion, so be precise. It is a time-limited carve-out, not a permanent free pass, and its scope is narrow. Do not plan a multi-year pipeline assuming the exemption will still be there — confirm the live window and treat the 2028 date as point-in-time and litigable.
Why the exemption exists
The exemption gives the supply chain time to build domestic cell and wafer capacity before the deeper content rules bite. It is a transition tool. That is why it has an end date and why that date can move as policy and capacity shift. Watch the MNRE order, not the rumour mill.
Open access vs net metering for compliance
The two grid routes carry different compliance shapes. This table sets them side by side so you can see where ALMM and DCR land for each. Treat every cell as point-in-time and verify.
Source: MNRE and SERC practice as understood on 20 Jun 2026. All cells are point-in-time — verify the current rule for your state and segment.
Group captive and the 26% rule
Group captive solar may need ALMM depending on the current order, while DCR is usually not required unless a scheme adds it. Group captive also has its own ownership and consumption tests, such as a minimum captive share reported at 26 percent. Verify both the ALMM applicability and the captive-share rules against the latest MNRE order and SERC regulations.
The captive structure is attractive because it can lower charges, but the ownership and consumption tests are strict and policed. Get the structure wrong and the captive benefit can be challenged. Our group-captive 26% guide covers the test, and the C&I and group-captive guide covers where ALMM is optional.
A developer compliance checklist
Before you commit modules on an open-access or wheeling project, run this short check.
- ALMM? Confirm whether your segment needs an ALMM-enlisted model under the live MNRE order.
- DCR? Confirm no scheme overlay adds a domestic-content requirement.
- Exemption? Check whether the open-access exemption window applies and its live end date.
- Captive test? If group captive, verify the ownership and consumption share.
- SERC rules? Read the relevant state open-access and wheeling regulations.
- BIS? Confirm module certification where it applies.
How SuryaHub helps open-access developers
Open-access compliance is a moving set of rules across MNRE, the SERC and the contract. SuryaHub can record whether each project needs ALMM, any exemption that applies and the captive-share details, then check the BOM against that rule in procurement and inventory before you order. It carries the same record into the approval workflow so the regulator file is consistent. SuryaHub is pre-revenue; the only real pilots are Suryantra Energy and RGESPL, and open-access and exemption rules change, so verify against the current MNRE order and the relevant SERC.
Get every open-access BOM right
See how SuryaHub tracks ALMM, exemptions and captive tests per project.
Related guides
Frequently asked questions
Does ALMM apply to open access and wheeling solar?+
ALMM often applies to open-access and wheeling solar, but the exact requirement depends on the current MNRE applicability order and the segment. Open access is more flexible than subsidy work, yet many projects still need an ALMM-enlisted model. Verify whether ALMM applies to your open-access or wheeling project under the latest MNRE order before you source modules.
Is DCR required for open access solar?+
DCR is usually not required for open-access and wheeling solar, because these are private commercial arrangements rather than domestic-content schemes. A DCR module becomes necessary only if a specific scheme or tender layered on top demands it. Verify the current rule, because applicability changes and a particular state or scheme may add a requirement you did not expect.
What is the open-access wafer exemption?+
The open-access wafer exemption refers to a window in which certain open-access and net-metering projects may be exempt from a deeper domestic-content requirement, reported to run to around 1 June 2028. The exact scope and end date are set by MNRE and can change. Confirm the current exemption window against the latest MNRE order before you rely on it for sourcing.
How is open access different from net metering for ALMM?+
Open access suits larger C&I and industrial loads and is governed by SERC open-access regulations plus MNRE, while net metering suits homes and smaller rooftops and runs through the DISCOM. ALMM is often required in both, but open access can carry exemptions that net metering does not. Verify the ALMM and any exemption rule for each route separately.
Does group captive solar need ALMM or DCR?+
Group captive solar may need ALMM depending on the current order, while DCR is usually not required unless a scheme adds it. Group captive also has its own ownership and consumption tests, such as a minimum captive share reported at 26 percent. Verify both the ALMM applicability and the captive-share rules against the latest MNRE order and SERC regulations.
How does SuryaHub help open-access developers with compliance?+
SuryaHub can record whether each open-access project needs ALMM, any exemption that applies and the captive-share details, then check the BOM against that rule before you order. SuryaHub is pre-revenue; the only real pilots are Suryantra Energy and RGESPL, and open-access and exemption rules change, so verify against the current MNRE order and the relevant SERC.
Sources & references
Open-access applicability, the exemption window and group-captive tests come from MNRE and the SERC. The exemption end date and the captive-share rule are point-in-time and can be litigated — verify against the latest MNRE order and the relevant state SERC before you act.
- Ministry of New & Renewable Energy (MNRE) ↗
The ALMM applicability orders and any open-access exemption windows.
- NISE DCR portal ↗
The DCR certificate context where domestic content is required.
- Central / State Electricity Regulatory Commissions ↗
Open-access, wheeling and group-captive regulations (verify the relevant SERC).
Written by the SuryaHub team · reviewed against MNRE, NISE & SERC sources · updated 20 June 2026.
Method: Open-access applicability and the exemption window follow MNRE and SERC rules and are re-checked regularly. The open-access/net-metering wafer exemption (reported to ~1 Jun 2028) and the 26% captive share are point-in-time and litigable — verify against the latest MNRE order and the relevant SERC. SuryaHub is pre-revenue; only Suryantra Energy and RGESPL are real pilots.
Change log: 20 Jun 2026 — first published.