Can Non-DCR Modules Be Used Under PM Surya Ghar If Subsidy Is Not Availed? A Logical Interpretation of MNRE Guidelines !!

The question of whether non-DCR (Non-Domestic Content Requirement) solar modules can be used for residential rooftop solar projects under the PM Surya Ghar: Muft Bijli Yojana (PMSG: MBY) when the consumer is not claiming subsidy (CFA) has become increasingly important, especially after the implementation of ALMM List-II requirements.

A careful reading of various MNRE Office Memorandums issued between 2024 and 2026 provides a fairly clear answer.

1. Original PM Surya Ghar Guidelines Allowed Non-DCR Modules Without CFA

The first and most important reference is the MNRE Office Memorandum No. 318/17/2024-Grid Connected Rooftop dated 07.06.2024, which laid down the operational guidelines for PM Surya Ghar.

Under Section 5(p) – "Give It Up", MNRE clearly stated:

Consumers who opt for installing rooftop solar systems without availing CFA under the scheme shall be free to do so without using domestically manufactured cells/modules (DCR).

The language used in the guideline is unambiguous.

The provision specifically states that consumers who:

• Choose not to avail Central Financial Assistance (CFA), or

• Voluntarily forgo subsidy through the "Give It Up" option,

are not required to use DCR-compliant cells/modules.

This means that the DCR requirement was linked to the subsidy benefit and not to the residential rooftop solar installation itself.

2. MNRE Further Clarified the Position in March 2026

To remove implementation difficulties, MNRE issued another Office Memorandum:

F.No. 318/119/2024-Grid Connected Rooftop dated 30.03.2026

In this OM, MNRE introduced a new functionality on the National Portal.

Paragraph 3 states that:

The PM Surya Ghar Portal introduces a new feature to allow applications without DCR Certificate. This provision is applicable only to consumers who opt out of subsidy benefits.

This clarification is extremely significant because it is not merely a policy statement—it is an actual portal-level implementation.

If the National Portal itself allows submission of applications without DCR certificates for consumers who are not claiming subsidy, it reinforces the original intent of the 07.06.2024 guidelines.

Therefore, as of 30.03.2026:

✅ Residential consumers not claiming CFA can apply through the PM Surya Ghar Portal without uploading a DCR certificate.

✅ Such projects can use non-DCR modules.

3. Impact of ALMM-II and the MNRE Order Dated 25.05.2026

The confusion largely emerged after issuance of:

MNRE Office Memorandum No. 283/63/2025-Grid Solar dated 25.05.2026

which introduced the implementation framework for ALMM List-II (Solar Cells).

Many stakeholders interpreted the order to mean that all residential rooftop projects must now comply with ALMM-II requirements.

However, Paragraph 9 of the same order contains a very important carve-out for residential consumers.

It states that:

Under PM Surya Ghar: Muft Bijli Yojana, consumers have the option to forgo CFA under the "Give It Up" campaign.

Further, it clarifies that:

Residential net-metering consumers who opt for this "Give It Up" campaign shall continue to be governed by the PM Surya Ghar Scheme Guidelines till the end of the scheme, i.e., 31 March 2027.

The paragraph also states that:

These residential net-metering consumers will mandatorily apply through the National Portal for PM Surya Ghar only.

4. What Does Paragraph 9 Actually Mean?

A logical reading of Paragraph 9 leads to the following conclusions:

Condition 1: Consumer Must Be Residential

The provision specifically refers to residential net-metering consumers.

Condition 2: Consumer Must Forgo CFA

The consumer must opt under the "Give It Up" mechanism and not claim subsidy.

Condition 3: Application Must Be Through PM Surya Ghar Portal

The order specifically requires such consumers to continue applying through the PM Surya Ghar National Portal.

Result

If all three conditions are satisfied:

• Residential consumer

• No CFA claimed

• Application through PM Surya Ghar Portal

then the consumer continues to be governed by the PM Surya Ghar Guidelines.

Since the PM Surya Ghar Guidelines already permit installations without DCR modules when CFA is not availed, the same principle continues to apply.

5. Harmonious Interpretation of All Three Orders

When the three MNRE documents are read together:

Document	Key Provision
07.06.2024 PM Surya Ghar Guidelines	No CFA → DCR not mandatory
30.03.2026 OM	Portal allows applications without DCR certificate for non-subsidy consumers
25.05.2026 ALMM-II OM (Para 9)	Residential "Give It Up" consumers continue under PM Surya Ghar Guidelines till 31.03.2027

The combined interpretation suggests that:

Residential consumers who do not avail subsidy and apply through the PM Surya Ghar National Portal may continue to install rooftop solar systems without DCR modules, in accordance with the PM Surya Ghar Scheme Guidelines, until the scheme's conclusion on 31 March 2027.

Important Caveat

While the above interpretation emerges logically from the existing MNRE orders, stakeholders should note that:

• ALMM-II implementation is still evolving.

• Distribution companies (DISCOMs) may adopt varying interpretations.

• A dedicated clarification from MNRE on the interaction between ALMM-II requirements and non-subsidy residential consumers would eliminate any residual ambiguity.

A formal clarification confirming that non-DCR modules remain permissible for residential "Give It Up" consumers applying through the PM Surya Ghar Portal would provide certainty to consumers, vendors, EPC companies, and DISCOMs alike.

Conclusion

Based on:

1. PM Surya Ghar Guidelines dated 07.06.2024,

2. MNRE clarification dated 30.03.2026, and

3. Paragraph 9 of the ALMM-II implementation order dated 25.05.2026,

there appears to be a strong regulatory basis to conclude that:

Residential consumers who do not avail CFA under PM Surya Ghar and apply through the National Portal can use non-DCR solar modules, subject to compliance with the scheme guidelines and applicable net-metering regulations.

The key requirement is not the use of DCR modules, but rather that the consumer must opt out of subsidy and process the application through the PM Surya Ghar National Portal.