There was a moment, somewhere in the last six weeks, when the industry quietly assumed the deadline would slip. Representations had piled up. The West Asia situation was choking supply chains. Logistics costs were running well above plan on routes carrying solar gear. Procurement teams were rewriting bills of materials in real time. By mid-May, the assumption that ALMM List-II would be pushed had become a near-consensus view in WhatsApp groups across the EPC trade.

The Ministry of New and Renewable Energy had a different read. In an Office Memorandum dated 25 May 2026, MNRE has confirmed that there will be no blanket extension. From 1 June, Net Metering and Open Access projects must source modules from ALMM List-I and cells from ALMM List-II. The domestic manufacturing thesis, which the List-II regime has anchored since notification, stands.

But the OM is not absolutist. Recognising that significant investment is already committed to projects in advanced stages of execution, MNRE has carved out a project-specific exemption mechanism. It is narrow. It is documentation-heavy. And it must be filed online, through the NISE portal, by 30 June 2026. There is no second window described.

Force Majeure, separately

Independent of the ALMM exemption track, the OM references Ministry of Finance guidance on the West Asia situation. Where developers can demonstrate that supply-chain disruption, logistics interruption or contractual delay is causally linked to the crisis, contract completion timelines may be extended by two to four months without penalty or additional cost. This is a different relief from the ALMM exemption. It speaks to timelines, not to procurement scope, and the two are not substitutes for one another. A project that misses the ALMM cut-off will still be required to use List-I modules and List-II cells; Force Majeure only buys it more time to do so.

Two doors that remain open

The exemption mechanism splits along a clean axis: how physically advanced is your project? If you can demonstrate full module installation before 1 June, you fall into Category I, the cleanest path, requiring only certified evidence from a government authority that the DC-side installation and module installation are complete.

If you cannot, the OM offers Category II, which is structurally harder. It demands four simultaneous proofs of project maturity: at least seventy-five percent of project land in your possession, financial closure achieved, in-principle connectivity approval received, and electrical drawings, including the Single Line Diagram, approved by the Electrical Inspectorate. The SLD approval, notably, must have been obtained by 1 May 2026, three weeks before the OM itself. Past those four gates, one of two physical-progress conditions must hold: either all required modules had arrived at site before the OM date, supported by GST invoices, e-Way bills and lorry receipts, or more than half of the modules were already installed before 1 June, with geo-tagged and time-stamped evidence on file.

These are not generous gates. They are calibrated to projects that were genuinely moving, not those that had merely been planned. A developer with land allotted but unmutated, financial closure pending sign-off, and modules at the factory rather than at site, is outside the door. The OM is explicit on this point: approvals will be examined project-by-project, case-by-case, by an Expert Committee constituted by MNRE. Nothing is automatic.

The commercial arithmetic

For projects that miss the cut, the procurement universe contracts. ALMM-approved cells and modules are not always price-competitive with global alternatives that some EPC contracts had been planned around. Landed cost goes up. Lead times stretch. Working capital cycles extend. For fixed-price EPC contracts already signed, the margin compression is real, and the conversations with off-takers about price variation clauses will need to begin quickly.

For developers whose projects fall cleanly inside Category I, the work shifts to documentation: securing the right government authority certifications, time-stamped photographic evidence, and complete invoice trails. For Category II, the documentation burden is several-fold higher. Every gate must be evidenced, and the SLD approval timestamp from before 1 May 2026 is a hard constraint that cannot be reconstructed after the fact.

The window to file

Exemption claims must be submitted online through the NISE portal at solarcpportal.nise.res.in by 30 June 2026. Physical applications will not be accepted. The Expert Committee will examine each claim independently, and the OM does not describe an appeal mechanism for refused claims. Developers preparing a submission would do well to engage counsel early and keep the documentation pack airtight on first reading.

The reading

Read pragmatically, the OM is a piece of careful regulatory engineering. It refuses to bend on policy intent. Domestic cell manufacturing is being protected, and a blanket extension would have signalled wobble at exactly the moment that domestic manufacturing capacity is ramping. But the ministry has acknowledged, in writing, that several otherwise-eligible projects are at genuine risk of being stranded by an enforcement deadline they cannot meet through no commercial failing of their own. The exemption mechanism is the ministry's attempt to thread that needle.

For the industry, the operational takeaway is clear. If you are still on track for 1 June, the deadline is your friend, since competitors who are not on track have just been forced into a cost structure you have already locked. If you are not on track, the next thirty-six days are for assembling either a Category I or a Category II claim, with documentation that an Expert Committee will accept on first reading.