Open access is the right to buy your electricity from someone other than your local distribution company, and use the network to have it delivered. For a factory or a large commercial site, it is often the single biggest lever on the energy bill.
For years, adding a battery to an open access or captive arrangement sat in an awkward regulatory grey area. That has now been cleared up, and the clarification is more consequential than it sounds.
The 2022 rules: opening the door
The Electricity (Promoting Renewable Energy Through Green Energy Open Access) Rules, 2022 did the structural work:
- The load threshold fell from 1 MW to 100 kW for green energy open access, with no minimum limit for captive consumers.
- Eligibility criteria, banking provisions and applicable charges were clarified, with exemptions from certain surcharges.
That threshold change matters more than any other line in the rules. At 1 MW, open access was for large industry. At 100 kW, it reaches mid-sized factories, commercial buildings, hotels, hospitals and warehouses — a vastly larger population of buyers. Our guide to open access solar in India covers the mechanics.
Adoption has been broad: as of November 2024, 28 of 29 states and union territories had adopted the framework.
The 2026 amendment: storage gets standing
The Ministry of Power notified the Electricity (Amendment) Rules, 2026 on 13 March 2026, and two changes matter for anyone considering a battery.
Hybrid configurations got statutory footing. Solar-plus-storage and wind-plus-storage arrangements now have an explicit basis in the rules, rather than depending on case-by-case interpretation. These are the configurations covered in solar plus storage and wind plus storage.
Storage-mediated consumption counts toward the captive threshold. Installations with co-located battery storage can count energy delivered through the storage system toward captive use.
Why this is a bigger deal than it reads: captive status depends on consuming a defined proportion of what your project generates. If it was unclear whether energy that had passed through a battery still counted as your consumption, then adding a battery put your captive status — and its commercial benefits — at risk. Very few finance directors would accept that trade. Making it explicit removes the obstacle entirely.
The comparison between captive and open access structures for factories is set out in captive versus open access solar for factories.
Banking, and why storage is the durable answer
Banking lets you push surplus generation onto the network and draw it back later — the grid acting as a notional store. It has always been the cheaper alternative to a battery, and it has always been less reliable, because banking terms are set by states and have been tightened repeatedly.
The rules are specific on one point: energy obtained through open access arrangements, whether from a third-party supplier or captive generation, does not form part of the permissible capacity of banked energy. Separately, green energy from open access has been exempted from a minimum banking stipulation.
The practical reading for a buyer: banking terms are a policy variable you do not control and which has moved against consumers over time. A battery on your own site is an asset you own, with terms that cannot be revised by a tariff order. That is the core argument in net metering versus storage for C&I.
What still varies by state
The central rules set a framework; states set what you actually pay. Wheeling charges, cross-subsidy surcharge and additional surcharge, banking terms and settlement periods, and application procedures all differ — sometimes dramatically. Two identical factories in two states can face very different open access economics.
So the correct sequence is: confirm the central position, then check your state’s current charges and orders, then model. Never the reverse.
What this means for you
- If you are a C&I buyer above 100 kW: you are inside the eligibility threshold, which is the main thing the 2022 rules changed. Whether it pays depends on your state’s charges, not on the central rules.
- If you already have a captive or open access solar arrangement: the 2026 clarification removes the reason not to add storage. Adding a battery lets you use evening-hours generation you currently bank on uncertain terms, or lose.
- If you are planning a hybrid project: solar-plus-storage and wind-plus-storage now have explicit statutory footing, which simplifies both approvals and financing conversations.
- If you want to know what it is worth on your site: the answer depends on your tariff, your load shape and your state’s charges. The savings calculator gives a first pass, and our team can work through the open access case with you — get in touch.
Open access rules, state charges, banking provisions and captive requirements change by notification and by state regulatory order, and state adoption of central rules varies in detail. Treat this as an August 2026 snapshot and verify the current position with your state regulator and distribution licensee before committing.