DCR and ALMM List-II are not the same rule

Since June there has been a steady supply of headlines saying non-DCR modules are banned in India. Distributors quote them. Customers read them. Some of your competitors are quoting on the strength of them.

They are not quite right, and the imprecision is expensive in both directions. Buy DCR stock for a project that never needed it and you have paid a premium for nothing. Buy non-DCR stock for a project that did need it and you have a system that cannot be commissioned.

Two different rules that people say interchangeably

DCR, the Domestic Content Requirement, is a procurement clause. It attaches to particular schemes and says that the cells and modules used must be manufactured in India. It is a condition of the scheme, not a property of the module.

ALMM is a list, or rather two lists. List-I is approved modules. List-II is approved cells, the things inside the modules. We wrote about what the two lists are and why List-II is the harder test when List-II first started to bite.

They are related, because the practical route to a domestically sourced cell is a cell from a List-II manufacturer, and that is why the two terms get collapsed into one. But they are not the same requirement, they attach to different things, and a module can satisfy one without satisfying the other.

The sentence worth memorising: DCR is about where the cell was made. ALMM is about whether the maker is on a list.

Which projects need which

Non-DCR modules are not banned everywhere. The requirement follows the category of project.

Categories where the ALMM List-II cell requirement applies:

• Government tender projects
• PM Surya Ghar residential rooftop
• PM KUSUM Components B and C
• Open access projects
• Net metered projects

The category that remains outside it:

• Purely private behind the meter commercial and industrial projects, with no government scheme, no subsidy and no grid incentive attached

That last line is the one being lost in the headlines, and it covers real work. A factory putting solar on its own roof for its own consumption, taking no subsidy and not exporting under a net metering agreement, is in a different position from a residential job claiming CFA.

Note also what the fourth bullet does. Net metering pulls almost all ordinary rooftop work inside the requirement, which is why "this only affects utility scale" was never true.

The date that should be in your calendar

There have been several exemptions since the rules started moving, and most of them have now closed. Two are reported to still be open:

• The net metering and open access blanket exemption, reported to run to 31 December 2026.
• The Give It Up exemption, for PM Surya Ghar consumers who forgo the CFA subsidy, reported to run to 31 March 2027.

If the first of those is accurate and is not extended again, the practical position is that from 1 January 2027 the net metering projects you are quoting today fall inside the List-II cell requirement. That is roughly one quarter away, which is shorter than the gap between sale and commissioning on a good many jobs.

What to write into the purchase order

A verbal assurance from a distributor is worth nothing at inspection, and "it is ALMM approved" is not an answer to the question you are asking.

Ask for four things in writing, on the invoice or a covering letter:

• The module model and its List-I status
• The cell manufacturer and its List-II status
• Whether the module is being sold to you as DCR compliant, stated in those words
• The date on which those statements were true

The fourth one matters more than it looks. When a supplier's List-II position changes, you want a dated document showing what you were told at the time you paid.

What a forced module swap does to the design

This is the second order effect that catches people, and it is the reason a compliance change is a design problem and not only a procurement one.

When a rule forces a module substitution, the replacement almost never matches the original wattage exactly. A 545 W module becomes a 550 W or a 535 W. That changes the string length, sometimes the inverter loading ratio, and on a constrained roof it changes the physical layout as well.

If the design exists as a drawing somebody made by hand, that substitution means redoing the drawing, then the bill of materials, then the generation estimate, then the proposal, and then explaining a new number to a customer who already signed. If it exists as a model, you change the module and the rest follows from it.

You will be doing this again. The rules here have moved four times in two years and there is no sign of them settling.

The short version

• DCR is a procurement clause about where cells are made. ALMM is a list of approved modules and cells. Not the same thing.
• Non-DCR modules are not banned outright. The requirement follows the project category.
• Government, subsidy linked, open access and net metered projects are inside it. Purely private behind the meter C and I is outside it.
• The net metering exemption is reported to expire on 31 December 2026, which is close.
• Get cell sourcing and DCR status in writing, dated, at purchase.

Sources

• Approved List of Models and Manufacturers (ALMM), Ministry of New and Renewable Energy
• Non-DCR solar panels after June 2026: what is actually banned, what is still allowed, Reslink Energy
• India to mandate DCR solar panels from June 2026 amid supply and cost concerns, SolarQuarter
• MNRE exempts select PM Surya Ghar projects from ALMM-II norms, Power Peak Digest