Gujarat raises the open access additional surcharge to Rs 0.99 a unit, one paisa below the same six months last year

The Gujarat Electricity Regulatory Commission has set the additional surcharge payable by open access consumers at Rs 0.99 per kWh for the six months from 1 October 2026 to 31 March 2027. The determination is Order No. 05 of 2026, issued at Gandhinagar on 16 September 2026 by Chairman Pankaj Joshi with Members Hiren Shah and Jatin N. Thakkar. It replaces the Rs 0.76 per kWh in force since 1 April, an increase of about 30.3 per cent.

The charge falls on commercial and industrial consumers of Gujarat's four state distribution companies (DGVCL, MGVCL, PGVCL and UGVCL, all under GUVNL) who buy their electricity from a third party through open access rather than from the distribution company whose wires they are connected to.

What the charge is actually for

The additional surcharge is not a tax on solar and not a penalty for leaving. It is a recovery mechanism for stranded fixed cost. A distribution company signs long-term power purchase agreements years ahead, against a forecast of the demand it expects to serve. When a consumer departs for a cheaper third-party supplier, the distribution company goes on paying the fixed capacity charge on generation it contracted for that consumer and can no longer sell. The additional surcharge bills that residue back to the consumer who left.

Whether that is reasonable depends entirely on the arithmetic, which is the part trade coverage usually omits and the part worth reading.

How Rs 0.99 was reached

GERC recomputes the figure every six months under a methodology it revised on 30 August 2022, working from actual data for the corresponding six months a year earlier. This determination uses 1 October 2025 to 31 March 2026.

Across that window the commission attributes 2,525 million units of stranded energy to open access consumers: 1,630 MU scheduled directly by them, plus 895 MU of apportioned balance. It nets off Rs 606 crore of demand charges those consumers had already paid, and applies a network cost adjustment factor of 8.77 per cent, worth roughly Rs 53 crore, on the reasoning that network costs are already recovered elsewhere and should not be collected twice. A transmission and distribution loss factor of 12.06 per cent is applied. The net recoverable stranded fixed cost comes to Rs 162 crore.

[UNVERIFIED: what follows is this publication's arithmetic on the reported figures, not a calculation the commission is reported to have set out. Order No. 05 of 2026 itself was not retrieved.] Rs 162 crore divided by the 1,630 MU of directly scheduled open access energy gives Rs 0.9939 per kWh, which rounds to the Rs 0.99 ordered. If that is the operative division, the recovery base is the energy open access consumers actually scheduled, and not the wider 2,525 MU the stranded cost is attributed to. The distinction matters, because it determines whether the next consumer to leave makes the charge cheaper or dearer for everyone else.

The comparison that is more useful than the 30.3 per cent

A rise of 30.3 per cent reads as a state making exit steadily more expensive. Three consecutive determinations do not support that reading.

For 1 October 2025 to 31 March 2026, the surcharge was Rs 1.00 per kWh. It was computed from October 2024 to March 2025 actuals, on Rs 188 crore of stranded cost attributable to open access consumers, reduced to Rs 149 crore recoverable after netting.

For 1 April to 30 September 2026 it fell to Rs 0.76 per kWh, under Order No. 02 of 2026, computed from April to September 2025 actuals, on a net recoverable stranded fixed cost of Rs 137 crore.

For 1 October 2026 to 31 March 2027 it is Rs 0.99 per kWh, on Rs 162 crore.

Measured against the same months a year earlier, the toll has fallen by one paisa. It has not risen by thirty per cent. The 30.3 per cent compares a winter half-year against a summer one, and the two are computed from different reference windows with different demand profiles. With only one summer observation on this record, it would be premature to call the difference seasonal, but it is enough to say the increase is not evidence of a charge ratcheting upward.

The underlying cost did rise, from Rs 149 crore to Rs 162 crore across the two winter windows, about 8.7 per cent. The per-unit charge stayed flat because the volume it is spread across grew at close to the same rate. [UNVERIFIED: the implied earlier base, Rs 149 crore at Rs 1.00 per kWh, is about 1,490 MU against 1,630 MU now, growth of roughly 9 per cent. This is an inference from the two figures, not a series the commission is reported to have published.]

Why it matters

The additional surcharge is the closest thing India publishes to an explicit price on leaving a distribution monopoly. Every other component of open access cost is either payment for a service genuinely rendered, such as wheeling and transmission, or a levy with its own separate rationale, such as the cross-subsidy surcharge. This one exists for no reason other than that the consumer left. Its level is therefore the most direct available measure of how expensive a state makes that decision, and it is reset twice a year in a document almost nobody outside the procurement teams reads.

It is also a charge with an unstable loop inside it. Stranded cost is divided by departing volume. If departures accelerate faster than stranded cost accumulates, the per-unit toll falls and exit becomes cheaper for the next consumer, which invites more departures. If contracted fixed costs grow faster than departures, the toll climbs on a shrinking group, and the last consumers out pay for the choices of the first. Which regime a state is in is not a matter of policy intent; it falls out of the division. Gujarat currently appears to be in the first, and a flat winter-on-winter number is what that looks like from outside.

For a commercial or industrial buyer weighing a third-party solar contract, the surcharge is one line among several. GERC separately revised the transitional banking charge for green open access with effect from 1 September 2026. [UNVERIFIED: that revision is tracked as a separate item and was not fetched for this piece.] The combined landed cost, not any single charge, is what moves a procurement decision, and the two charges last moved in opposite directions.

What is still unknown

[NEEDS DATA: the gross stranded fixed cost before the Rs 606 crore demand-charge netting, which would show how much of the claim the netting step actually removes.]

Whether captive consumers, green open access consumers and conventional open access consumers are treated identically under this order, and what exemptions apply to each.

Whether the commission publishes the departing-volume series itself. That would settle whether the recovery base is genuinely growing or whether the reconstruction above is wrong.

[NEEDS DATA: the all-in landed cost per kWh of open access solar in Gujarat with the new surcharge, wheeling, transmission, cross-subsidy surcharge and banking charge all included.]

Sources

Mercom India, 15 September 2026, for the Rs 0.99 figure, the 30.3 per cent increase and the period: https://www.mercomindia.com/gujarat-hikes-additional-surcharge-for-open-access-consumers-to-%E2%82%B90-99-kwh

SolarQuarter, 16 September 2026, for Order No. 05 of 2026, the bench, the Rs 162 crore net recoverable stranded cost, the Rs 606 crore of netted demand charges, the 8.77 per cent network cost adjustment factor, the 12.06 per cent loss factor, the 2,525 MU and 1,630 MU energy figures and the 30 August 2022 methodology: https://solarquarter.com/2026/09/16/gerc-sets-inr-0-99-kwh-additional-surcharge-for-gujarat-open-access-consumers-from-october-2026/

SolarQuarter, 19 March 2026, for Order No. 02 of 2026, the Rs 0.76 per kWh determination, its April to September 2025 reference window, the Rs 137 crore net recoverable stranded fixed cost and the 8.77 per cent network cost deduction: https://solarquarter.com/2026/03/19/gerc-fixes-%E2%82%B90-76-kwh-additional-surcharge-for-open-access-consumers-for-april-september-2026-in-gujarat/

Mercom India on the preceding Rs 0.76 per kWh determination: https://www.mercomindia.com/gujarat-cuts-additional-surcharge-for-open-access-power-to-%E2%82%B90-76-kwh

Energetica India on the Rs 1.00 per kWh determination for October 2025 to March 2026, the Rs 188 crore attributable and Rs 149 crore recoverable stranded cost: https://www.energetica-india.net/news/gerc-imposes-inr-1kwh-additional-surcharge-on-open-access-consumers