By Sarthak Takyar and Sakshi Bansal
Competition and choice are relatively new concepts for Indian consumers. Till not too long ago, electricity, like many other public utility services, was under the monopoly of local distribution companies, which were the sole suppliers of power in their respective areas of jurisdiction. This began to change with the liberalisation of the sector and the introduction of open access through the Electricity Act, 2003. The act aimed to foster competition by allowing eligible consumers to buy electricity from suppliers of their choice.
With renewables becoming more affordable than thermal power, the renewable open access route has become even more crucial for commercial and industrial (C&I) customers, who have ambitious climate targets and need to procure a certain percentage of renewables for meeting their electricity needs. With most discoms not providing a green tariff for the supply of only renewable electricity, many C&I players prefer the open access route. “This route has redefined energy procurement for C&I consumers, offering lower tariffs, greater control over the energy mix and an alternative to discoms’ inefficiencies. By leveraging open access, businesses can now optimise costs while achieving their sustainability goals,” says R. Sunder, business head, C&I, India, Hero Future Energies.
However, the uptake of open access transactions, especially for renewables, has been slow. State-level inconsistencies in charges, exemptions and policies created uncertainty and discouraged wider adoption. While some states offered waivers or concessions to promote renewable energy, others frequently revised open access charges, disrupting business models and investment decisions. Moreover, the eligibility threshold, typically set at 1 MW, excluded a large pool of smaller C&I consumers interested in tapping the renewable open access market.
To address these issues, the central government introduced the Electricity (Promoting Renewable Energy Through Green Energy Open Access) Rules, 2022 (GEOA Rules 2022), which significantly lowered the threshold to 100 kW, allowing smaller C&I consumers to participate in the green power market. The rules provided much-needed clarity by defining eligibility norms, banking provisions and associated charges, along with offering key exemptions such as relief from surcharges. To further strengthen the framework, two amendments were introduced in 2023. These updates allowed demand aggregation across multiple connections and clarified issues related to banking charges and settlement timelines, making the open access mechanism more efficient, flexible and inclusive for a broader spectrum of users.
Status across states
While the regulations were passed by the centre, on-ground implementation depended on individual state-level policies. Initially, adoption across states was gradual. However, over the past two years, the landscape has shifted significantly. By May 2025, the GEOA framework had gained strong traction, with 23 out of 29 states and union territories formally adopting the regulations.
In 2023, 11 states proactively embraced the GEOA framework. These were West Bengal, Karnataka, Madhya Pradesh, Tripura, Haryana, Sikkim, Punjab, Chhattisgarh, Uttarakhand, Maharashtra and Odisha. This momentum continued into 2024, with another 11 states – Arunachal Pradesh, Gujarat, Telangana, Manipur, Mizoram, Andhra Pradesh, Meghalaya, Jharkhand, Nagaland, Goa and Bihar – joining in. A few other states have only released draft regulations so far. These are Uttar Pradesh, Himachal Pradesh, Tamil Nadu, Delhi and Assam. All of these drafts were circulated in 2024. Kerala is the only state that is yet to initiate any GEOA-related policy, making it the lone outlier in an otherwise comprehensive roll-out.
“Progressive policies across Karnataka, Maharashtra, Gujarat and Tamil Nadu have led the charge in enabling open access and fostering a cleaner energy ecosystem. Meanwhile, states such as Haryana, Rajasthan and Uttarakhand are expanding opportunities for C&I consumers to participate in this transformative regime,” says Sunder.
According to data from the Green Open Access Registry Portal, there have been a total of 1,127 GEOA injection applications over the last five years (2021–2025), with the top five GEOA-injecting states being Karnataka (384 applications), Rajasthan (119), Gujarat (79), Maharashtra (66) and Andhra Pradesh (57). These states are rich in renewable energy resources and have robust generation capacity and infrastructure, making them key contributors to green energy injection into the grid. Meanwhile, there were a total of 2,216 drawee applications, with the top five GEOA-drawee states being Tamil Nadu (737), Uttar Pradesh (356), Andhra Pradesh (197), Gujarat (156) and Telangana (110). This was likely driven by their high C&I energy demand, which fuels the consumption of green power under open access.
Since the introduction of the GEOA rules, India’s C&I renewable energy open access market has seen strong growth. As highlighted in the report, “Impact of Green Energy Open Access”, by the Institute for Energy Economics and Financial Analysis (IEEFA) and JMK Research & Analytics, the market achieved a compound annual growth rate of 46 per cent between financial years 2022 and 2024, expanding from 10.2 GW in 2022 to a cumulative 18.7 GW by the end of 2024. Rahul Mishra, senior vice-president and head, C&I business, BluPine Energy, presents a similar estimate, noting that the GEOA market accounts for just 15–18 GW of India’s 232 GW of installed renewable energy capacity as of May 2025, representing less than 10 per cent of the overall renewable pie.
The report goes on to add that the influence of the GEOA framework became especially pronounced between financial years 2023 and 2024, during which annual installed capacity soared by 90.4 per cent. A significant portion of this growth – over 70 per cent – was driven by five states: Gujarat, Tamil Nadu, Karnataka, Maharashtra and Rajasthan. Gujarat and Rajasthan stood out in particular, contributing 1.43 GW and 0.98 GW, respectively, in financial year 2024.
This strong growth trend has continued into 2025. Rajasthan, already a frontrunner in renewable energy, has formally adopted the GEOA framework. Haryana has also revised and strengthened its GEOA guidelines.
Challenges and the way forward
Despite the positives of the GEOA rules, several challenges hamper achievement of their full potential. One of the most important developments — lowering the eligibility limit to 100 kW — has technically opened the market to micro, small and medium enterprises (MSMEs), which make up a large part of India’s industrial base. However, adoption remains limited, even in industrial hubs such as Gujarat and Maharashtra. For many MSMEs, lack of awareness about the mechanism, limited in-house technical capacity and concerns around project bankability are major hurdles. Small-scale consumers often struggle to secure financing or find developers willing to aggregate demand at such a scale, especially in the absence of long-term purchase commitments or credit-worthy offtake guarantees. As a result, while open access is now more inclusive on paper, practical uptake among smaller C&I players – especially MSMEs – remains a challenge.
State-level bottlenecks, such as delays in approvals, deviations from central guidelines and administrative inefficiencies, are slowing down progress. For instance, although the central rules mandate a 15-day approval window, Maharashtra allows 30 days, while states such as Madhya Pradesh and Chhattisgarh have no clear timelines. Similarly, standby charges vary widely. Although set at 25 per cent of energy charges by the centre, they could be as high as 125 per cent in states such as Chhattisgarh and Andhra Pradesh. “The momentum of GEOA faces real threats. Policy misalignment across states, retrospective implementation of regulations by states, uncertainties such as the proposed rollback of the inter-state transmission system (ISTS) waiver and challenges in banking, wheeling and SLDC approvals risk stalling investor confidence and industrial uptake,” says Mishra.
Measures to promote domestic manufacturing, such as the enforcement of the Approved List of Models and Manufacturers and the imposition of basic customs duties, have also created temporary disruptions and impacted the pace of project buildout. While these policies aim to strengthen India’s renewable manufacturing base, in the short term, they have led to supply constraints and delays in procurement, affecting timelines for open access project execution.
In fact, in January 2025, the High Court of Karnataka struck down the centre’s Electricity (Promoting Renewable Energy Through Green Energy Open Access) Rules, 2022, as well as the Karnataka Electricity Regulatory Commission’s Terms and Conditions for Green Energy Open Access Regulations, 2022 under the legal reasoning that the centre overstepped its authority under the Electricity Act, 2003 by attempting to regulate open access and wheeling/banking, areas that fall within the exclusive jurisdiction of the state commissions. In March 2025, the state announced the Karnataka Open Access Regulations, 2025. This has set a precedent for other states.
Another market risk, going forward, will be the gradual phase-out of the ISTS waiver. “This waiver for renewable energy projects has been a major cost-saving measure, enabling C&I consumers to procure green power at competitive prices. This has supported the commercial viability of long-term renewable power purchase agreements and helped lower industrial power costs, boosting manufacturing competitiveness under the Make in India initiative,” says Mishra.
He cautions that if the ISTS waiver is not extended beyond June 2025, the viability of industrial green energy contracts will be at serious risk. Projects currently in the pipeline and expected to come up within the next two years may face abandonment due to unviable pricing structures. Such a setback could slow down future renewable energy adoption for industrial decarbonisation and affect India’s export competitiveness, especially in carbon and energy-intensive sectors tied to global market access.
Power market dynamics are changing. Alongside renewable electricity, C&I consumers are also demanding battery storage solutions and, in some cases, even green hydrogen. Going forward, open access solutions will have to incorporate these technologies. “The way forward is to shift the conversation from intermittent green power to dependable, despatchable clean energy. Integrated open access solutions, combining wind, solar and battery storage, offer precisely that: 24×7 renewable power suited to the demands of hard-to-abate sectors. All in all, as global value chains tilt toward greener inputs and carbon accountability, India’s clean industrial growth will depend on how effectively it scales open access,” says Mishra.
