MNRE extends the ALMM framework to include solar wafers, covering the full manufacturing value chain

On 17 March 2026, the Ministry of New & Renewable Energy (MNRE) issued an amendment to the Approved Models and Manufacturers of Solar Photovoltaic Modules (ALMM) Order, extending the ALMM framework to solar wafers through the introduction of ALMM List‑III. The amendment marks a decisive policy shift toward end‑to‑end domestic integration of India’s solar manufacturing value chain—modules, cells, and now wafers.

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While the effective date for wafer compliance is 1 June 2028, the amendment has immediate implications for bidding strategies, contracting structures, supply‑chain planning, and manufacturing investments. Stakeholders across the ecosystem—developers, EPC contractors, manufacturers, and lenders—will need to start aligning project pipelines with this future compliance requirement.

What Has Changed?

1. Introduction of ALMM List‑III (Wafers)

MNRE proposes a new ALMM List‑III specifically for solar wafers, to be operational from 1 June 2028. From this date onward, projects covered under ALMM will be required to source:

• Modules from ALMM List‑I
• Cells from ALMM List‑II
• Wafers from ALMM List‑III

This effectively completes the ALMM chain from wafer to module.

2. Conditions for Issuance of ALMM List‑III

ALMM List‑III will not be notified unless all of the following thresholds are met:

• At least three independent wafer manufacturing units
• No common ownership or control (direct or indirect)
• Aggregate wafer manufacturing capacity of at least 15 GW per annum

Further, any wafer manufacturer seeking enlistment must also possess commensurate ingot manufacturing capacity, ensuring that listed wafer capacity reflects actual upstream integration.

Implication:

The framework is designed to prevent superficial compliance and ensure genuine domestic capability, not merely downstream processing.

Impact on Projects: Key Scenarios

1. Projects Bid Before the Cut‑Off Date

For projects where:

• The last date of bid submission falls on or before the Cut‑Off Date (defined as 7 days after the first ALMM wafer list is issued),

The following will apply:

• Mandatory use of ALMM‑listed modules and cells
• Exemption from ALMM‑listed wafers, irrespective of commissioning date

This exemption also extends to cases where PPAs are signed before the Cut‑Off Date, even if EPC or supply tenders are issued later.

2. Projects Bid After the Cut‑Off Date

Projects with bid submission dates after the Cut‑Off Date must:

• Explicitly include ALMM compliance clauses for modules, cells, and wafers in tender/RfS documents

This has significant implications for:

• Long‑term supply contracts
• Price risk allocation
• Back‑to‑back compliance warranties

1. Net‑Metering and Open Access Projects

• Commissioned before 1 June 2028: Exempt from wafer compliance
• Commissioned on or after 1 June 2028: Mandatory use of ALMM‑listed modules, cells, and wafers

4. Behind‑the‑Meter Captive Projects (Government‑Owned)

A phased compliance regime applies:

• Before 1 June 2026: Only ALMM modules required
• 1 June 2026 to 31 May 2028: ALMM modules and cells required
• On or after 1 June 2028: Full ALMM compliance (modules, cells, wafers)

5. Thin‑Film and Integrated Manufacturing Units

Thin‑film modules and fully integrated manufacturing units enlisted under ALMM List‑I are deemed compliant with wafer and cell requirements, recognising technological and structural differences.

Structural Changes to ALMM Lists

From the effective date, MNRE will maintain multiple sub‑lists to accommodate exempted project categories:

• ALMM List‑I(a): Modules using non‑ALMM cells and wafers
• ALMM List‑I(b): Modules using ALMM cells but non‑ALMM wafers
• ALMM List‑II(a): Cells using non‑ALMM wafers

Manufacturers failing to align with the full ALMM chain risk delisting from the primary ALMM lists for covered projects.

Strategic Implications for Stakeholders

For Developers

• Future bids must price in wafer‑level domestic sourcing risk
• Transitional projects require careful bid‑date and commissioning alignment
• Increased diligence on upstream supplier compliance

For EPC Contractors

• Stronger contractual pass‑through clauses will be essential
• Supply chain mapping will need to extend beyond module suppliers

For Manufacturers

• Accelerated investment decisions in ingot and wafer capacity
• Potential consolidation among players unable to meet scale thresholds

For Lenders and Investors

• ALMM compliance becomes a bankability parameter
• Greater scrutiny of supply contracts and compliance representations

Regulatory Parity and Level Playing Field Considerations

A notable feature of the amendment is the asymmetric transitional treatment accorded to different categories of projects. While Government‑owned behind‑the‑meter captive projects benefit from both cut‑off date grandfathering and a phased compliance pathway for modules, cells, and wafers, Open Access (OA) and Net‑Metering (NM) projects do not enjoy comparable pipeline protection.

OA and NM projects are granted only a limited exemption from wafer compliance for projects commissioned prior to 1 June 2028, without the benefit of bid‑date‑linked grandfathering or phased transition. This distinction could raise level playing field concerns, particularly where projects compete for the same capital, manufacturing capacity, and execution resources.

From a policy perspective, the differential treatment may increase regulatory uncertainty for private and C&I‑focused developers and could influence investment decisions in the OA/NM segment. Stakeholders may therefore seek greater clarity or alignment in transitional provisions to ensure competitive neutrality across project categories.

What to Watch Going Forward

1. Issuance of Procedural Guidelines for wafer enlistment
2. Timeline for achieving the 15 GW threshold
3. Market response in terms of capacity announcements and JVs
4. Price and availability impacts on near‑term projects

Conclusion

The inclusion of wafers under ALMM is not merely a regulatory update—it is a structural re‑engineering of India’s solar manufacturing policy. By pushing compliance upstream, MNRE is signalling long‑term commitment to domestic value creation, while simultaneously reshaping risk allocation across solar projects.

Stakeholders who proactively align procurement strategies, contracts, and investment plans with this evolving framework will be best positioned to manage transition risks and capture emerging opportunities.

This analysis is based on MNRE’s Office Memorandum dated 17 March 2026 amending the ALMM Order.