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					</table>Changes to banking regulations, settlement mechanisms, and open access charges across states are altering the economics of renewable power procurement for commercial and industrial (C&amp;I) consumers, according to developers operating in the segment.
The impact is particularly visible in Tamil Nadu and Maharashtra, where restrictions on banking and time-of-day (ToD) settlement are reducing the flexibility available to consumers to match renewable generation with their electricity demand.
The changes come as India&#8217;s solar open access market continues to expand. India added nearly 6 GW of solar open access capacity in the first half of 2026, up 42% year-over-year from 4 GW. Cumulative installed capacity reached 36 GW as of June 2026, according to Mercom India&#8217;s <a href="https://www.mercomindia.com/india-solar-open-access-capacity-up-6-gw-in-1h-2026" target="_blank" rel="noopener">Q2 2026 India Solar Open Access Market Report</a>.
However, savings for C&amp;I consumers have come under pressure. Mercom previously <a href="https://www.mercomindia.com/rising-landed-costs-shrink-savings-for-solar-open-access-consumers" target="_blank" rel="noopener">reported</a> that rising power purchase agreement tariffs and regulatory charges were increasing the landed cost of solar open access across most states.
Tamil Nadu Banking Changes
Tamil Nadu&#8217;s Green Energy Open Access Regulations, 2025, <a href="https://www.mercomindia.com/tamil-nadu-notifies-green-energy-open-access-regulations-2025?" target="_blank" rel="noopener">introduced</a> an 8% banking charge for solar and wind projects and monthly settlement of banked energy.
Developers say mandatory monthly settlement means surplus energy can no longer be carried forward annually. Unutilized energy at the end of the month is settled with the distribution licensee at 75% of the applicable tariff.
They estimate that the changes add roughly ₹0.05 (~$0.0005)/kWh to the landed solar tariff, reducing savings for C&amp;I consumers.
The effect could be greater for wind projects because generation is seasonal and may not correspond with monthly consumption. Developers said eliminating banking for third-party wind open access projects could reduce potential contract sizes by up to 30%.
Restrictions on ToD banking create another constraint because energy generated during off- peak periods cannot be adjusted against consumption during peak periods. The resulting mismatch increases the importance of matching generation with a consumer&#8217;s load profile.
Industry insiders say monthly banking provisions and ToD slot restrictions are reducing flexibility for C&amp;I consumers with higher evening demand.
Solar plus storage configurations are consequently becoming more relevant for managing energy consumption and reducing purchases of peak-hour grid electricity.
Captive and group captive structures remain favorable because of cross-subsidy surcharge exemptions, but accurate project sizing and generation-consumption matching have become increasingly important. The banking framework also requires closer forecasting and 15-minute settlement management.
The regulatory changes are also affecting procurement decisions.
Several C&amp;I consumers in Tamil Nadu are taking longer to finalize renewable power procurement because of uncertainty surrounding banking policies and settlement mechanisms.
They are seeking greater regulatory clarity before signing long-term power purchase agreements, particularly for projects scheduled for commissioning in 2026. Rising grid tariffs continue to support interest in solar open access, but uncertainty over savings projections has lengthened decision-making cycles.
Mercom previously found that open access solar growth had <a href="https://www.mercomindia.com/open-access-solar-growth-slows-in-maharashtra-and-tamil-nadu" target="_blank" rel="noopener">slowed</a> in Tamil Nadu and Maharashtra, with banking and tariff reforms influencing market activity in both states.
Maharashtra Restricts Time Shifting
Developers have raised similar concerns over the changing economics of open access in Maharashtra.
The Maharashtra Electricity Regulatory Commission <a href="https://www.mercomindia.com/maharashtra-revises-energy-banking-rules-in-modified-multi-year-tariff-order" target="_blank" rel="noopener">revised</a> its energy banking framework earlier this year, restricting the withdrawal of banked energy based on ToD slots.
Stakeholders say the same slot banking restrictions have reduced the flexibility previously available through grid-based energy adjustment.
Solar generation credits are restricted to corresponding daytime consumption periods, making storage more relevant for industries operating during the evening or at night.
Grid support charges and other grid-related costs can further affect project economics. Changes in banking rules and ToD structures are also requiring revisions to PPAs, financial models, energy scheduling, and investment assumptions.
Maharashtra&#8217;s revised multi-year tariff and ToD tariff structures could reduce open access savings because lower DISCOM tariffs during certain periods narrow the difference between grid electricity and open access power.
Solar open access tariffs could increase from ₹3 (~$0.0315) to ₹3.2 (~$0.0337)/kWh previously to ₹3.75 (~$0.0394) to ₹4 (~$0.0421)/kWh.
Developers also cite restrictions on time-slot settlement, rising open access charges, and upfront cross-subsidy surcharges as pressures on captive consumers and project developers. They contend that open access charges must remain within 20% of the applicable DISCOM tariff to support long-term project viability.
Mercom found that the same slot-banking restrictions could affect the internal rate of return of solar open access projects by changing the savings assumptions used when projects were developed.
Storage Gains Relevance
Changes in Tamil Nadu and Maharashtra are increasing the relevance of battery energy storage because consumers can no longer rely on banking to the same extent to manage differences between renewable generation and electricity consumption.
Storage allows solar electricity generated during the day to be shifted to periods when consumer demand and grid tariffs are higher.
Storage-linked contracts and stronger demand management are becoming more important as developers and consumers adjust PPAs and energy schedules to the revised banking structures in Tamil Nadu and Maharashtra.
Hybrid projects combining solar and wind can provide another option by producing electricity across a broader portion of the day.
Lower Charges Improve Economics Elsewhere
The regulatory direction differs in Odisha and Haryana, where reductions in some open access charges are improving renewable power economics for industrial consumers.
In Odisha, developers referred to reductions in cross-subsidy surcharges of approximately 10% for TPCODL, 58% for TPNODL, and 4% for TPSODL. Consumers also benefit from a ₹0.50 (~$0.0052)/kWh concession on electricity duty and a 50% exemption on cross-subsidy surcharge.
In Haryana, developers cited a 2% reduction in cross-subsidy surcharge, a 20% reduction in transmission charges, and a 29% reduction in wheeling charges for C&amp;I consumers.
However, timely DISCOM approvals for wheeling and banking remain bottlenecks in both markets.
Gujarat has also recently reduced the cost of banking renewable energy. In August, the Gujarat Electricity Regulatory Commission <a href="https://www.mercomindia.com/gujarat-cuts-green-energy-open-access-banking-charges-to-%E2%82%B91-kwh" target="_blank" rel="noopener">reduced</a> green energy open access banking charges to ₹1 (~$0.0105)/kWh for the period from September 1, 2026, to March 31, 2027.
The differences among states mean the PPA tariff alone does not determine the savings available to an open access consumer.
Banking charges, cross-subsidy surcharge, transmission and wheeling charges, grid support charges, electricity duty, ToD tariffs, settlement periods, and the treatment of surplus electricity all affect the final landed cost.

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