The Approved List of Models and Manufacturers (“ALMM”) is a regulatory framework established by the Ministry of New and Renewable Energy (“MNRE”), Government of India (“GoI”), to ensure the quality, reliability, and traceability of solar photovoltaic (“PV”) modules and manufacturers – initially, intended for government-supported solar projects and has now been expanded to third party open access and privately set-up captive power projects. Only the models and manufacturers listed under the ALMM framework are eligible for use in such projects – including those that benefit from subsidies, incentives, or are implemented by government agencies. By maintaining a list of certified manufacturers and models, ALMM intends to standardize the industry, promote domestic manufacturing, and establish safeguards against low-quality imports.

The ALMM list, which has undergone some key amendments in recent years, is intrinsically aligned to the GoI’s objective of developing India as a major manufacturing hub and reducing dependence on imports. In this context, the GoI introduced the “Production Linked Incentive Scheme – National Programme on High Efficiency Solar PV Modules” in April, 2021, and accordingly issued the guidelines for awarding solar PV modules manufacturing tenders for Tranche – I (in April, 2021) and Tranche – II (in September, 2022).

I. Regulatory Overview and Chronology of ALMM

ALMM (Solar)

The ALMM framework was first introduced by the MNRE through the order dated January 2, 2019 (“ALMM Order”). The ALMM Order laid down the foundation for a compulsory registration system for solar photovoltaic (“PV”) modules and cells, conceived as List-I for modules and List-II for cells. The rationale was to address the solar sector’s concerns about traceability, quality, and energy security in a sector with asset lifecycle ranging from 15 to 25 years. The first ALMM List-I (Modules) was published on March 10, 2021, featuring about ~8.2 GW of enlisted capacity. Since then, the list has expanded rapidly and, in August 2025, encompasses over 100 manufacturers with more than 100 GW annual capacity.

In 2022, the scope of the ALMM Order was expanded to include open access and net-metering projects, while exemptions were provided for projects where applications had been made prior to October 1, 2022. In March 2023, due to supply constraints and COVID-era disruptions, MNRE had suspended the enforceability of ALMM for the financial year 2023-2024 while exempting projects commissioned upto March 31, 2024 from complying with the ALMM framework. This suspension was lifted on March 29, 2024, re-instating the ALMM compliance from April 1, 2024 onwards without any blanket exemptions. The MNRE, however, clarified that “behind-the-meter” solar power plants used solely for captive consumption by a consumer or group of consumers are exempted from the ALMM framework (both for solar PV modules and solar PV cells).

One of the significant reforms in the ALMM framework has been the introduction of ALMM List-II (Cells) – MNRE’s office memorandum dated December 9, 2024, declared that ALMM List-II compliance would be mandatory from 1 June 2026, with a well-considered cut-off to protect ongoing projects. Therefore, the projects whose last date of bid submission was on or before December 9, 2024 were exempted from ALMM List-II requirements irrespective of their commissioning dates. However, projects awarded thereafter were required to comply with the ALMM List-II requirements even if their commissioning preceded June, 2026. The first ALMM List-II (Cells) was published on July 31, 2025, listing multiple manufacturers with capacities, efficiencies, and validities extending to 2029. Starting from June, 2026 onwards, the remaining modules listed on ALMM List-I are required to use cells from List-II, failing which they risk de-listing, with certain projects expressly exempted^[1]. On September 12, 2025, the MNRE has issued the draft amendments to the ALMM Order, under which the scope of the ALMM framework has been proposed to be further expanded to include ‘wafers’ under a new ALMM List-III – with compliance requirements proposed to commence from June 1, 2028.

Most recently (i.e., on September 23, 2025), the MNRE has also issued the updated frequently answered questions (“FAQs”), clarifying the implementation of ALMM for solar PV cells in India. The updates specify the applicability of ALMM requirements based on project types, bid submission dates, and commissioning timelines, including detailed provisions for exemptions and mandatory compliance. Notably, while as a general principle all projects commissioned on or after June 1, 2026, must comply with both ALMM List-I (Modules) and List-II (Cells) requirements, projects with the last date of bid submission on or before August 31, 2025 are exempted from the requirement to use solar PV cells from ALMM List-II (Cells), regardless of their commissioning date. These projects must still use solar PV modules from ALMM List-I (Modules), but the use of ALMM-listed solar PV cells is not mandatory. The FAQs also address the relationship between ALMM and domestic content requirement (“DCR”) provisions under various government schemes, clarify rules for net-metering and open access projects, and outline the implications for project transfers and state-level schemes, ensuring stakeholders have clear guidance on ALMM compliance moving forward.

RLMM (Wind)

Similar to the solar PV modules and solar PV cells, the MNRE established the Revised List of Models and Manufacturers (“RLMM”) in November, 2018 to standardize and assure quality in wind turbine generators (“WTGs”). RLMM listed WTG models are those that have obtained and/or undergone type certification, performance validation, safety compliance, and suitability testing for Indian conditions. On July 31, 2025, MNRE introduced a critical reform, through an office memorandum, renaming RLMM to ALMM (Wind)^[2]. This reform mandated that critical turbine components – blades, towers, generators, gearboxes, and special bearings must be sourced from a forthcoming ALMM (Wind Turbine Components) list. It also requires manufacturers to establish local research and development centres. Further, on October 29, 2025, the MNRE has issued standard operating procedures for enlistment/certification of WTG and WTG components under the RLMM framework.

Under the original RLMM framework (2018-2025), manufacturers had to submit type certificates, design evaluations and manufacturing system certificates. The 2025 transition to ALMM (Wind) expanded these requirements, introducing inspection of WTG component and stipulating that only approved suppliers of key components could be used for WTGs listed under the RLMM framework. Compliance with RLMM is mandatory for all government-supported projects, competitive tenders, and open access projects. It is also important to note that the eligibility for concessional customs duty certificates has been linked to inclusion under the RLMM framework, whereby customs benefit can be availed only upon compliance with the RLMM requirements.

II. Aims and Policy Objectives of ALMM

The ALMM is designed to achieve several objectives, including quality assurance, traceability through factory-specific approvals, promotion of domestic manufacturing in the renewable energy industry, and to support the Government’s cross-sector ‘Make in India’ policy goal vis-à-vis the sectoral ‘Production Linked Incentive’ framework. In terms of objective, the ALMM restricts the use of non-listed modules and/or WTGs in eligible projects, thereby altering the procurement strategies of developers and engineering, procurement and construction contractors. Although the scope of the ALMM has undergone periodic alterations, including through suspensions and reinstatements with grandfathering provisions regarding project milestones (such as bid date, date of execution of the power purchase agreement, module purchase order date, and commissioning dates), the ALMM now applies to a broader range of projects, including third-party open access and captive projects, not just government-supported projects.

Listing and Procedural Reforms

Throughout 2021-2024, the MNRE has issued several amendments to ALMM List-I (Modules) and made further updates, adjusting efficiency norms and application requirements. The notable procedural reforms include: (a) substantial reduction in application and inspection fees (up to 80%) to be listed as part of the ALMM/RLMM; (b) extension of listing validity from 2 to 4 years; and (c) provisions for faster provisional enlistment, including time-bound processing of applications for final enlistment of suppliers.

The process for listing involves manufacturers applying on a per-factory, per-model basis and includes the submission of type test reports, factory audits, and quality control documentation. The listings are model-specific with the possibility of suspension or de-listing for any non-compliance with the ALMM framework. Any change in the bill of materials or manufacturing process typically necessitates re-validation.

Intersection with Other Regulatory Regimes

The ALMM framework intersects with various other regulatory regimes, both in terms of technical compliance and in terms of benefits and incentives, which include the following:

• Bureau of Indian Standards (“BIS”): BIS is the national standards body of India, responsible for the development and implementation of standards, certification, and quality assurance for products and systems. In this regard, BIS certification is a pre-requisite for ALMM/RLMM registration – in the absence of BIS certification, a manufacturer or model cannot be listed under the ALMM/RLMM framework.
• Solar Production Linked Incentive (“PLI”) Scheme: India’s “Production Linked Incentive Scheme – National Programme on High Efficiency Solar PV Modules”, launched in two tranches (as discussed above), was aimed at catalysing large-scale integrated manufacturing. Tranche – I supported ~8.7 GW of capacity, while Tranche – II awarded ~39.6 GW, bringing the total PLI-backed capacity to ~48 GW as on date. The PLI scheme and ALMM together create a policy framework that not only boosts domestic manufacturing but also ensures that only quality-assured, domestically produced modules are used in renewable projects in India.
• Basic Customs Duty (“BCD”): BCD is a standard import duty levied on goods imported to India. For solar PV cells and modules, the GoI has imposed significant BCD (e.g., 40% on modules, 25% on cells from April, 2022 onwards) to discourage imports and reduce reliance on foreign manufacturers. It is important to note that even if an imported equipment includes payment of BCD, it cannot be used in utility-scale or government-backed projects unless it is ALMM/RLMM listed. In this regard, please note that as on date, most foreign manufacturers are not enlisted under the ALMM/RLMM framework.

• Incentives Under Government Schemes: All central and state government-supported renewable energy projects – including flagship schemes, such as the PM-KUSUM and rooftop solar programs, mandate the use of solar modules and cells that are listed under the ALMM framework. This requirement is explicitly stated in the official guidelines, scheme documents, and tender conditions issued by the MNRE and implementing agencies. During the tendering and bidding process, MNRE and its implementing agencies set pre-qualification criteria that require bidders to specify the make and model of solar PV modules they intend to use. Therefore, only those modules that are enlisted in the prevailing ALMM list are accepted.
• Goods and Services Tax (“GST”): The GST on solar modules, cells and WTGs was reduced from 12% to 5% effective from September 22, 2025. Lower GST reduces the overall cost of ALMM-listed (mostly domestic) modules, making them more competitive against imported modules (which may not be ALMM-listed and are subject to additional duties like BCD). Accordingly, while reduction in GST does not alter the regulatory requirements of ALMM, it makes compliance with ALMM relatively economical for developers, thereby also encouraging greater adoption of quality-assured, ALMM-listed modules in renewable energy projects.

  
  III. Non-Compliance with ALMM

Typically, non-compliance scenarios include procurement or installation of modules or WTGs not listed under the ALMM or RLMM framework (where procurement of ALMM/RLMM-listed equipment is mandatory for such projects), or instances which involve procurement from listed manufacturers but deploying unlisted models or different bill of materials than those approved, or misrepresentation or falsified documentation to show compliance, mixing compliant and non-compliant components, and continuing to use the equipment after a manufacturer or the specified model has been suspended or de-listed (without proper disclosure). Any non-alignment with related standards, such as BIS for solar PV modules, while claiming ALMM compliance, would also constitute non-compliance under the prevailing framework. The consequences of such non-compliance may have a severe impact on defaulting projects, including the following:

(a) Loss of Incentives: The projects awarded under the MNRE schemes are usually eligible for financial incentives, subsidies, or funding, however, the release of such funds/subsidies is strictly conditional upon the proof that ALMM-listed modules have been used. Non-compliant projects may become ineligible for central or state subsidies (such as, viability gap funding) that are tied to ALMM compliance, under MNRE or other government schemes.

(b) Administrative and Other Consequences:

• The MNRE, under various schemes and programmes implemented by it, also prescribes DCR conditions, which mandates use of domestically manufactured solar PV modules and solar PV cells. The MNRE has clarified that violation of the DCR conditions can lead to several consequences^[3] which include filing of criminal action against the defaulting entity, blacklisting of the developer for a period of 10 years, forfeiture of bank guarantees, etc.
• With the implementation of the Bharatiya Nyaya Sanhita, 2023 (“BNS”), non-compliance or fraudulent practices related to ALMM requirements can attract significant penal consequences. For instance, if a supplier misrepresents the origin, certification, or ALMM status of solar modules or cells to gain eligibility for government projects or subsidies, such conduct may fall under Section 316 (cheating) of the BNS, which penalizes anyone who, by deceit, induces another to deliver property or to do or omit to do anything which one would not do or omit if such person were not so deceived.
• Use of non-conforming products where BIS certification or other technical standards are mandated can result in regulatory action, including possible product recalls or prohibition on their sale or use if safety or conformity issues are established.
• Administrative actions may include show-cause notices, blacklisting, termination, and financial recoveries. These typically begin with the issuance of a show-cause notice, requiring the concerned party to explain the non-compliance or alleged irregularity within a stipulated timeframe. Failure to provide a satisfactory response or confirmation of the violation, can lead to blacklisting of the manufacturer or supplier from participating in government tenders and schemes in future. In addition, the agency may proceed with termination of contracts or cancellation of project approvals where non-compliant modules or cells have been used, which can halt project execution and result in significant financial loss. Furthermore, authorities are empowered to initiate financial recoveries, including the clawback of subsidies, incentives, or payments already disbursed, and may also seek compensation for any losses or damages suffered by the government agencies or end-users due to the non-compliance. These administrative actions are often taken in parallel with, or in addition to, penal actions under other applicable laws, underscoring the critical importance of strict adherence to the ALMM framework.

Endnotes:

[1] As per the MNRE office memorandum dated September 23, 2025, if the last date of bid submission for projects is on or before June 1, 2026, then such projects will be required to comply with ALMM List-I but not ALMM List- II.

[2] For ease of reference, we have referred to ALMM (Wind) as RLMM in this article.

[3]https://cdnbbsr.s3waas.gov.in/s3716e1b8c6cd17b771da77391355749f3/uploads/2023/10/202310171791450430.pdf