MNRE Issues Proposal for ALMM List-III Covering Solar Wafers and Ingots

On March 17, 2026, the Ministry of New and Renewable Energy (MNRE) issued an Office Memorandum amending the “Approved Models and Manufacturers of Solar Photovoltaic Modules (Requirements for Compulsory Registration) Order, 2019.” The amendment introduces ALMM List-III, a regulatory category for solar PV wafers and ingots. Effective June 1, 2028, the measure aims to deepen upstream integration and curb reliance on Chinese imports by extending domestic sourcing mandates further into the solar value chain.

Notification Thresholds and Capacity Requirements

The MNRE has established specific industrial benchmarks that must be satisfied before List-III is officially notified. Crucially, List-III functions as an “Integrated Ingot and Wafer” list, as manufacturers must demonstrate linked capabilities to be eligible. The conditions for implementation include:

Independent Units: The presence of at least three independent wafer manufacturing units operational within India.
Ownership Restrictions: These units must operate without any common ownership or control, whether direct or indirect.
Aggregate Capacity: Enlisted units must achieve a minimum combined manufacturing capacity of 15 GW per annum.
Ingot-Wafer Linkage: To ensure upstream value chain deepening, wafer manufacturers must possess an equivalent ingot manufacturing capacity to qualify for enlistment.

Cascading Sourcing Framework and Mandatory Scope

The new framework establishes a hierarchical sourcing requirement designed to drive backward integration across the domestic manufacturing ecosystem. Sourcing for projects under the ALMM purview must follow this sequence:

Solar PV Modules: Must be sourced from models and manufacturers in ALMM List-I.
Solar PV Cells: Modules in List-I must utilize cells sourced from ALMM List-II.
Solar PV Wafers/Ingots: Cells in List-II must utilize wafers and ingots sourced from ALMM List-III.

The “Effective Date” Rule From the June 1, 2028, effective date, only solar PV modules utilizing both ALMM-compliant cells and ALMM-compliant wafers will remain in List-I. Manufacturers failing to meet these integrated requirements face delisting.

To service “Exempted Projects”—those bid out before the mandate takes effect—the MNRE will maintain separate sub-categories to provide a transition path for the industry:

List-I(a): Modules using cells and wafers not enlisted in ALMM.
List-I(b): Modules using ALMM-enlisted cells but non-enlisted wafers.
List-II(a): Solar cells using non-enlisted wafers.

Implementation Timeline and Cut-Off Mechanisms

The transition is governed by a “Cut-Off Date” mechanism to protect the existing procurement pipeline. Per the official Office Memorandum, the Cut-Off Date is defined as one month after the date of issuance of the first ALMM list for wafers.

Bidding Exemptions: Projects where the last date for bid submission falls on or before this Cut-Off Date are exempt from the wafer requirement, regardless of their eventual commissioning date.
Grandfathering Provisions: If a project owner submitted a bid or signed a Power Purchase Agreement (PPA) prior to the Cut-Off Date, the exemption persists even if subsequent tenders for EPC services or module/cell supply are issued after the date.
Future Mandates: Projects bidding after the Cut-Off Date must explicitly mandate ALMM List-III compliance for wafers within their tender or Request for Selection (RfS) documents.

Specific Project Exemptions and Phased Compliance

Net-Metering and Open Access Projects under net-metering or open access arrangements commissioned before the June 1, 2028, effective date are exempt from the wafer mandate. Projects commissioned on or after this date must achieve full compliance across Lists I, II, and III.

Government-Owned Captive Projects Behind-the-meter captive projects owned by government entities are subject to a three-phase compliance timeline based on commissioning dates:

Prior to June 1, 2026: Mandatory use of ALMM-listed modules only.
June 1, 2026, to May 31, 2028: Mandatory use of both ALMM-listed modules and cells.
On or after June 1, 2028: Full mandatory compliance for modules, cells, and wafers.

Thin-Film Technology and Deemed Compliance Thin-film technology-based modules enlisted in List-I and manufactured in integrated units are granted “deemed compliance” status for both cell and wafer requirements. This provision identifies US-based First Solar as a key industrial beneficiary.

Cell-Level Exemptions Any project specifically granted an exemption from the requirement to use ALMM-enlisted solar cells is automatically granted an equivalent exemption from the wafer requirement.

Regulatory Context and Polysilicon Outlook

The introduction of List-III serves as a critical expansion of the 2019 ALMM Order. While the policy pushes for upstream integration, the MNRE confirmed there will be no relaxation in Domestic Content Requirement (DCR) provisions for existing schemes, including PM-KUSUM (Components B & C), PM Surya Ghar: Muft Bijli Yojana, and the CPSU Scheme Phase-II.

The government is also moving to address the final gap in the value chain: polysilicon. Currently, India has no commercial-scale production of polysilicon (“NA” status), though Adani and Reliance have announced plans. MNRE is reportedly in discussions with the Finance Ministry to launch a dedicated Production Linked Incentive (PLI) scheme for polysilicon to further reduce global supply risks. Procedural guidelines for wafer enlistment under List-III are expected to follow shortly.

Technical Value Chain and Industrial Snapshot

The solar manufacturing sequence progresses from Polysilicon (refined silicon) to Ingots (cast blocks), then Wafers (sliced sheets), which are processed into Cells and assembled into Modules.

India’s current domestic capacity for wafers and ingots is limited to approximately 2 GW. However, supported by PLI tranches, the industry is targeting significant expansion by FY28, with projected capacities of 34.69 GW for wafers and 23.86 GW for ingots. In contrast, downstream module capacity has already surpassed 100 GW as of August 2025.

Commenting on the extension of the ALMM framework, Suhas Donthi, CEO of Emmvee Group, stated: “Backward integration and upstream expansion are core to our strategy. A significant portion of upstream components remains import-dependent, making this policy a critical step toward building a truly self-reliant and integrated solar manufacturing ecosystem in India. We welcome the move wholeheartedly and are fast-tracking execution.”