ALMM-II is not DCR and is not implementable as on date ??

The Indian solar industry is standing at one of its most critical turning points.

With the Office Memorandum issued by the Ministry of New and Renewable Energy on 9th December 2024 regarding implementation of ALMM List-II for Solar PV Cells from 1st June 2026, the Government aims to strengthen domestic solar manufacturing and reduce dependency on imports.

On paper, the intention appears positive.

But the real question is:

Is India actually prepared for ALMM-II implementation?

Or are we heading towards:

• supply shortages,

• project delays,

• market manipulation,

• higher prices,

• compliance confusion,

• and possible corruption?

This article raises some of the most important practical, technical, legal, and market-related questions which every EPC company, installer, developer, investor, DISCOM, and consumer must understand before ALMM-II becomes mandatory.

Understanding ALMM-II

The Approved List of Models and Manufacturers (ALMM) framework already mandates usage of approved solar modules under ALMM List-I for many government-linked and regulated projects.

Now, the Government proposes implementation of:

• ALMM List-II for Solar PV Cells,

• effective from 1st June 2026.

This means:

• Solar modules will remain in ALMM-I only if they use cells from manufacturers enlisted in ALMM-II.

At first glance, this looks like a push towards “Make in India”.

But the deeper issue is:

Is there enough domestic capacity and infrastructure to support such implementation?

The Biggest Contradiction in the Office Memorandum

The Office Memorandum itself states:

List-II was not issued earlier because domestic solar PV cell capacity was lower than demand.

This was a logical reason.

However, the same condition substantially exists even today.

Despite claims of manufacturing expansion:

• India’s effective DCR/ALMM-II compatible cell capacity still remains far below actual market demand.

• Many manufacturers continue depending on imported cells.

• Several large brands are already facing supply shortages.

So the obvious question becomes:

If insufficient capacity was the reason for postponement earlier, why is the same policy being implemented now?

Policy decisions cannot be based purely on projected expectations.

They must be based on:

• actual available manufacturing capacity,

• stable supply chains,

• affordability,

• and implementation readiness.

The “Expected Capacity Increase” Problem

The Government’s basis for implementation appears to be the expectation that domestic solar PV cell capacity would increase substantially.

But expectations and ground reality are two different things.

Even after additional investments:

• actual operational cell manufacturing capacity remains limited,

• utilization rates vary,

• integrated production is concentrated among a few large players.

The market today still does not have:

• adequate supply diversity,

• transparent traceability,

• or pricing stability.

Implementing ALMM-II under such conditions may create artificial scarcity rather than strengthen the industry.

Why ALMM-II is NOT Equal to DCR

One of the biggest misconceptions in the industry is:

“If a module is DCR, then it is automatically ALMM-II compliant.”

This is incorrect.

The Office Memorandum nowhere states that every DCR module automatically qualifies under ALMM-II.

The reality is:

• All ALMM-II compliant modules may be DCR,

• But all DCR modules are NOT necessarily ALMM-II compliant.

Why?

Because ALMM-II is based on:

• enlistment status of the cell manufacturer,

• not merely the domestic origin of cells.

This creates a massive compliance confusion.

A module may:

• use Indian-manufactured cells,

• qualify as DCR,

• yet still become non-compliant if the cell manufacturer was not enlisted in ALMM-II at the relevant time.

This means:

DCR alone is not the actual criteria.

The Biggest Practical Problem: Traceability

Currently, the solar industry lacks a centralized traceability mechanism.

There is no national system to digitally verify:

• which module used which cell,

• whether the cells were ALMM-II compliant,

• whether the module was manufactured before or after a particular date,

• or whether the same model number represents DCR or non-DCR variants.

This becomes even more dangerous because:

The same module model numbers are often used for:

• DCR modules,

• Non-DCR modules,

• Imported cell variants,

• Domestic cell variants.

So how will field verification happen?

Will authorities:

• physically inspect factories?

• depend on invoices?

• rely on declarations?

• manually verify every project?

Without a digital verification system, implementation risks becoming:

• inconsistent,

• discretionary,

• and corruption-prone.

The Risk of Corruption & Market Manipulation

Whenever:

• compliance becomes difficult,

• documentation becomes complex,

• and verification lacks transparency,

the risk of corruption automatically increases.

Without a centralized portal:

• fake compliance declarations may emerge,

• project approvals may become subjective,

• field-level harassment may increase,

• and selective enforcement may occur.

This is particularly dangerous for:

• rooftop solar consumers,

• MSME EPC companies,

• small installers,

• and open-access developers.

The industry requires:

transparency before enforcement.

What Happens to Existing Inventory Purchased Before 1st June 2026?

This is one of the most serious unresolved issues.

Suppose:

• a developer purchases ALMM-I listed modules before 1st June 2026,

• those modules are legally compliant at the time of purchase,

• but commissioning happens after 1st June 2026.

Now what?

Will those modules suddenly become unusable?

What if:

• the cells were Indian-made,

• but the manufacturer was not yet enlisted in ALMM-II?

This creates enormous commercial uncertainty.

No industry can function properly when:

• compliance changes overnight,

• inventories become risky,

• and policy interpretation remains unclear.

The Commissioning Deadline Problem

The Office Memorandum effectively creates a “before 1st June 2026” and “after 1st June 2026” compliance structure.

But in reality, project commissioning is not a one-day activity.

Commissioning involves:

• installation,

• inspections,

• net-metering approvals,

• DISCOM processes,

• synchronization,

• documentation,

• and portal approvals.

If a project is installed before 1st June but approval is delayed afterward:

• who becomes responsible?

• the consumer?

• the installer?

• the DISCOM?

The policy currently leaves too many grey areas.

Is India Ready Even for PM Surya Ghar Demand?

Under PM Surya Ghar Muft Bijli Yojana:

• only a fraction of the target households have reportedly been solarized,

• while a massive number still remain pending.

Government calculations themselves indicate very high future demand for:

• modules,

• cells,

• rooftop systems.

If the existing DCR ecosystem itself struggles to fulfill even current demand, then what will happen when:

• Net Metering projects,

• Open Access projects,

• and commercial installations also shift toward mandatory ALMM-II linked sourcing?

The market may face:

• severe shortages,

• rising prices,

• and project delays.

Why Are Major Manufacturers Already Facing Shortages?

Another important question the industry is asking:

If sufficient domestic capacity already exists, then why are some major brands reportedly facing supply shortages for months?

Possible explanations include:

1. Actual capacity is lower than claimed,

2. Production utilization is lower,

3. Supply chains are constrained,

4. Manufacturers are prioritizing selective projects,

5. Or the market is entering artificial scarcity.

If supply is already tight before full ALMM-II implementation, what will happen afterward?

The Pricing Question Nobody Wants to Discuss

Currently, the market reportedly shows massive price differences between DCR modules.

One module may sell near:

• ₹21/Wp,

while another may reach:

• ₹32/Wp.

This raises critical questions:

• Which manufacturer is actually efficient?

• Which one genuinely needs protection?

• Why should consumers bear inflated pricing?

Some manufacturers:

• do not even manufacture their own cells,

• yet still operate within the protected ecosystem.

Meanwhile, vertically integrated players may dominate pricing power.

Without competitive safeguards, ALMM-II may unintentionally create:

• monopolistic behavior,

• profiteering,

• and reduced affordability.

Why MNRE Needs More Time Before Implementation

The biggest reality is simple:

The ecosystem is still not fully prepared.

Before mandatory implementation, the following systems are essential:

1. National Traceability Portal

A centralized digital platform where:

• module serial numbers,

• cell source details,

• manufacturing data,

• and project registration can all be tracked transparently.

2. Standardized Nomenclature System

Every module should clearly identify:

• DCR / Non-DCR,

• ALMM-II compliance,

• cell origin,

• manufacturing month/year,

• technology type,

• wattage,

• and grade category.

Without this:

• field verification becomes impossible.

3. Transparent Verification Mechanism

Compliance should not depend on:

• manual interpretation,

• selective inspections,

• or paperwork manipulation.

Digital verification must become mandatory.

4. Stable Demand-Supply Balance

Implementation should happen only when:

• adequate domestic capacity exists,

• supply is stable,

• and pricing remains competitive.

5. Transition Period for Existing Inventory

Modules legally purchased before implementation should remain protected for a reasonable transition period.

Otherwise:

• businesses may face heavy losses,

• and market confidence may collapse.

This Debate is NOT Against Indian Manufacturing

Supporting domestic manufacturing is important for:

• energy security,

• employment,

• industrial growth,

• and strategic independence.

But successful policy implementation requires:

• planning,

• transparency,

• infrastructure,

• and market readiness.

Protection without preparation can damage the very industry it intends to strengthen.

Final Thoughts

ALMM-II may eventually become an important step for India’s solar manufacturing ecosystem.

But implementation without:

• adequate capacity,

• traceability,

• transparency,

• and market readiness may create more problems than solutions.

The solar industry does not need confusion.

It needs:

• clarity,

• fairness,

• accountability,

• and practical implementation.

Before enforcing ALMM-II nationwide, the Government should:

• reassess real domestic capacity,

• create proper digital infrastructure,

• establish transparent verification systems,

• stabilize supply chains,

• and consult all stakeholders.

Because if implementation fails, the impact will not remain limited to manufacturers alone.

It will affect:

• consumers,

• installers,

• EPC companies,

• MSMEs,

• developers,

• and India’s solar growth journey itself.