Maharashtra proposes to let rooftop credits lapse above 3 kW, mandate batteries above 100 kW, and cap a transformer at 70 per cent

On 22 September 2026 the Maharashtra Electricity Regulatory Commission put seven draft regulations out for comment in a single public notice, Advt. No. 39/2026. The one that matters to anyone with a roof is the draft MERC (Grid Interactive Rooftop Renewable Energy Generating Systems) Regulations, 2026, which would repeal the 2019 rooftop regulations along with their 2023 and 2024 amendments and replace them. Comments close at 5 PM on 12 October 2026, and counter submissions are accepted until 15 October.

The headline provision is storage. Clause 4.2 requires every new grid interactive rooftop system and every new behind the meter system above 100 kW to be equipped with an energy storage system of at least 50 per cent of installed renewable capacity for a minimum of two hours, or 25 per cent for four hours. A floor applies underneath that: a minimum of 1 kWh per kW of installed capacity up to 2030, and 2 kWh per kW thereafter. The threshold is not arbitrary in its effect. One hundred kilowatts is roughly where Indian commercial and industrial rooftop begins to make sense, so the mandate lands on the segment that was working rather than on households.

The second provision is a ceiling. Clause 5.1 says the cumulative capacity of all systems under net metering, net billing, group net metering and gross metering connected to a given distribution transformer or feeder shall not exceed 70 per cent of its rated capacity. The licensee may allow more, but only on the strength of a detailed load study it carries out itself. Clause 5.2 at least makes the queue visible: the licensee must publish transformer wise available capacity and installed rooftop capacity every quarter, in a prescribed format. Read with clause 4.1, which grants connection on a non-discriminatory, transformer wise, first come first serve basis, the right to connect becomes a right to a place in a line with a lid on it.

The third provision is the one least likely to be reported and most likely to change behaviour. Clause 11.4.2(d) provides that unutilised surplus banked energy lapses at the end of each banking period for any consumer whose contracted renewable capacity exceeds 3 kW. The generating station receives renewable energy certificates for the lapsed units; the consumer receives nothing. Below 3 kW the treatment is different: surplus at the end of the banking period is purchased by the licensee at a rate the Commission notifies annually, based on the volume weighted annual average market clearing price across the day ahead and real time markets during solar hours, defined as 09:00 to 17:00. Clause 11.4.3 then instructs the Commission to determine, in the retail tariff order, both a fixed banking and standby charge in rupees per kW per month on contracted renewable capacity and a variable charge in rupees per kWh. For consumers on time of day tariffs, banked energy is adjusted against consumption starting from the highest energy charge slot downwards, which is the one clause in the set that favours the prosumer.

What this adds up to is a redefinition of who counts as a small consumer worth compensating. Maharashtra is the largest rooftop market in India and its regulations get copied, so the 3 kW line is worth watching wherever else it turns up.

What is not established should be said plainly. The repeal clause carries provisos on migration and on a prosumer option that were not read end to end, so this brief does not assert how existing systems are grandfathered, and the commencement clause complicates it further by saying applications received after publication of the draft will be processed under the existing regulations yet remain subject to the new provisions once notified. The explanatory memorandum, which would give the Commission's own reasoning for the 3 kW line and the 70 per cent cap, has not been read. The draft distribution open access regulations and the draft battery energy storage regulations issued in the same notice have not been read either, and they may move the same consumers in the opposite direction.