On 24 March 2026, the Central Electricity Regulatory Commission notified the CERC (Terms and Conditions for Renewable Energy Certificates for Renewable Energy Generation) (First Amendment) Regulations, 2026. The amendment reshapes the REC framework in three substantial ways: it introduces a technology-based multiplier system, formally recognises Virtual Power Purchase Agreements (VPPAs) within REC issuance, and extends eligibility to self-consumption RE projects that don't qualify as captive under Rule 3 of the Electricity Rules, 2005.
For C&I buyers building RCO compliance strategies, and for developers structuring offtake, the amendment changes both the math and the menu of available routes.
What CERC has changed
The amendment inserts new definitions tying the REC framework to broader policy: Designated Consumer under the Energy Conservation Act 2001, Renewable Consumption Obligation (RCO), and Virtual Power Purchase Agreement (VPPA) as defined in the CERC Power Market Regulations 2021. These aren't cosmetic — they create the legal bridge between the REC system and the RCO regime that now governs renewable compliance for large consumers.
Three operational shifts matter most:
- Multipliers replace flat issuance: Different RE technologies now generate RECs at different rates per unit of generation. The era of "one MWh, one REC" is over for many technologies.
- VPPA RECs get a separate track: A new Regulation 14A governs how RECs flow under VPPAs — non-tradable, tied to the buyer, and extinguishable on RCO compliance.
- Eligibility broadens: Self-consumption RE projects that don't meet captive thresholds are now eligible to issue RECs for the consumed portion — closing a gap that previously penalised on-site solar at non-captive ownership structures.
The multiplier system — winners and losers
The revised Appendix-1 of the regulations sets indicative multipliers based on a scoring system. The numbers below are the values widely reported following the notification:
| Technology | Multiplier |
|---|---|
| Solar PV, Wind, Hybrid (solar + wind) | 1.0 |
| Hybrid renewable projects | 1.5 |
| Small Hydro | 2.5 |
| Biomass, Biofuel cogeneration | 3.0 |
| Large Hydro and Pumped Hydro Storage | 3.0 |
| Municipal Solid Waste & cogeneration | 3.0 |
| BESS charged from renewable sources | 3.0 |
| Offshore Wind | 4.0 |
The economic logic is straightforward: technologies that are commercially mature and cost-competitive (solar, onshore wind) carry a multiplier of 1, while technologies that need policy support to scale receive higher multipliers. Offshore wind at 4× is the standout — a clear signal that the government wants to catalyse a sector that has so far struggled to attract investment in India.
VPPAs get a regulatory framework
The amendment introduces Regulation 14A specifically governing RECs issued under VPPAs. The mechanics are tightly defined:
- RECs generated from VPPA arrangements are transferred to the consumer or designated consumer who is the counterparty to the agreement
- The consumer can use these RECs to meet RPO or RCO requirements
- Once used for compliance, the RECs are extinguished — they cannot be re-traded or re-used
- Surplus RECs may be carried forward but cannot be traded on power exchanges or through traders
- Generators must report VPPA-linked projects to the central agency, which handles the post-compliance extinguishment
This neatly closes a long-standing ambiguity: under the previous regime, VPPAs sat in a regulatory grey zone — financial instruments mimicking physical PPAs without clear REC attribution. The new framework gives VPPAs a clean status as RCO-compliance instruments, while ensuring the underlying RECs don't double-count by appearing on the open market.
This pairs with the CERC VPPA Guidelines issued in December 2025, which separately established VPPAs as non-tradable, non-transferable specific delivery (NTSD) over-the-counter contracts with a minimum duration of one year.
Self-consumption that isn't captive: now eligible
The amended Regulation 4 expands REC eligibility to include "renewable energy generating plants with self-consumption that do not qualify as captive generating plants under the Electricity Rules, 2005."
This is more significant than it sounds. Until now, on-site or behind-the-meter solar that didn't meet the strict 26% equity / 51% consumption captive thresholds was effectively shut out of the REC mechanism. The 2026 amendment opens that door. Self-consumed RE generation by entities that could not structure as captive — for example, smaller consumers, multi-occupant industrial parks, or specific corporate structures — can now claim RECs against their consumption.
The implications for C&I buyers stuck between full captive and full grid procurement are material: a third route to RCO compliance with structural flexibility.
What this means for C&I buyers and developers
The amendment, taken together with the broader RCO framework now operationalising, has four practical consequences:
- Re-price your REC procurement strategy. If you've been planning RCO compliance through generic REC purchases, the multiplier system materially changes which RECs will be cheaper and more abundant on exchanges. Solar and wind RECs (1×) will likely remain the deepest market; expect premium pricing for offshore wind, biomass, and BESS-RE RECs.
- VPPAs become a serious RCO tool. Large buyers — particularly designated consumers under the Energy Conservation Act — should evaluate VPPAs against physical PPAs and pure REC purchases. The financial-settlement structure of VPPAs avoids transmission/wheeling/CSS exposure, while the new framework gives clean REC attribution for compliance.
- Self-consumption opens up for non-captive structures. If you have on-site or behind-the-meter solar that isn't captive-structured, the new Regulation 4 may now let you claim RECs against that generation. Review your projects against the eligibility test.
- Developers should price the multiplier into project economics. A BESS-charged-from-RE project at 3× generates three times the REC stream of a vanilla solar project per unit of net generation. Hybrid configurations at 1.5× similarly improve REC monetisation. Project IRRs will look different post-amendment.
The First Amendment 2026 is one of the more consequential adjustments to India's REC regime since the framework was first introduced. By tying RECs more closely to RCO and VPPAs, broadening eligibility, and introducing multipliers that nudge technology mix, CERC has effectively repositioned the REC from a residual compliance instrument to a core lever in the C&I renewable procurement toolkit. C&I buyers and developers who model these changes carefully — and move early — will capture the most economic value.
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