Supported by strong policy frameworks and investments, India is rapidly scaling up its domestic solar manufacturing. One of the key policy initiatives in this space was the introduction of the Approved List of Models and Manufacturers (ALMM) List I for solar modules, which was further reinforced with the announcement of ALMM List II for solar cells in December 2024.
This growing emphasis on self-reliance in solar manufacturing was further strengthened in September 2025 with the proposal to introduce ALMM List III for solar wafers, which will come into effect from June 1, 2028. According to the draft amendment released by the MNRE, ALMM List III for wafers will be issued once it includes at least three wafer manufacturing units, with an aggregate manufacturing capacity of at least 15 GW per annum. To qualify for enlistment, a wafer manufacturer must also have an ingot manufacturing capacity equal to the wafer capacity it seeks to enlist under ALMM.
In addition, projects exempted from using ALMM-listed solar cells will also be exempted from using ALMM-listed wafers. Once List III becomes effective, all solar PV modules in ALMM List I must use solar PV cells from ALMM List II, and those cells must, in turn, use wafers from ALMM List III. However, to streamline categorsiation, the draft also specifies that separate lists will be maintained from the effective date. These are:
- List I(a) for solar PV modules using cells and wafers not included in the ALMM
- List I(b) for solar PV modules using ALMM-listed cells but not ALMM-listed wafers
- List II(a) for solar PV cells using wafers not listed in ALMM
Projects with bid submission deadlines on or before the cut-off date must use solar PV modules from ALMM List I and cells from ALMM List II, but are exempt from using wafers from ALMM List III, even if commissioned after the effective date. The cut-off date will be one month after the first issuance of ALMM List III for wafers.
This exemption also applies to projects for which bids have been submitted or power purchase agreements signed before the cut-off date, followed by tenders for engineering, procurement and construction or the supply of modules or cells. Projects with bid submission dates after the cut-off must specify in tender documents that the modules, cells and wafers should comply with ALMM requirements.
The draft further specifies that open access and net metering projects commissioned before the effective date are exempt from using wafers under ALMM III, but must comply with ALMM-listed modules and cells. However, projects commissioned on or after the effective date must use ALMM-compliant modules, cells and wafers.
For government-owned behind-the-meter and captive projects, projects commissioned before June 1, 2026, must only use ALMM-listed modules. Projects commissioned between June 1, 2026, and the effective date (June 1, 2028) must use ALMM-listed modules and cells, while those commissioned on or after the effective date must use ALMM-listed modules, cells and wafers.
The way forward
The Indian solar sector is poised for another pivotal shift as the MNRE releases its draft proposal to introduce ALMM List III for solar wafers. This step is both timely and strategic in advancing India’s goal of self-reliance in solar manufacturing. By fostering a supply chain that is not dependent on China, the policy will create promising export opportunities for India to countries seeking diversified sourcing options and adopting the “China+1” strategy.
With strict quality and capacity criteria for List III inclusion and a mandate to align module procurement with domestically produced wafers, the initiative will bridge the capacity gap between modules, cells and wafers. Moreover, as wafer and ingot manufacturing is typically less capital-intensive but technologically more demanding than cell production, it could attract early investments and enable rapid expansion.
While the initiative marks a significant step towards self-reliance, the implementation of draft ALMM List III may be complex, particularly as it mandates the maintenance of separate lists [List I(a), I(b), II (a)] from the effective date. Further, combining wafers and ingots into a single category may complicate compliance as it requires wafer manufacturers to also have ingot production capacity equal to their wafer output. In addition, the 15 GW annual threshold for wafers seems inadequate to support India’s projected capacities of over 100 GW for cells and around 160 GW for modules by 2030. As a result, dependence on imports for wafers and ingots in the coming years will likely continue despite the successful implementation of the draft policy update.
Overall, while the draft proposal represents an ambitious and forward-looking vision, its success will depend on phased and carefully planned implementation to ensure that the ongoing pace of solar development is not disrupted. Going forward, the effective implementation of policy measures will be crucial to provide certainty to both manufacturers and investors
By Sakshi Bansal
