GUJARAT · REGULATORY TOPIC

Banking in Gujarat

Draft — not yet in force Gujarat Electricity Regulatory Commission (GERC) Last reviewed 20 August 2026

What this means

GERC's Draft Banking Charge Regulations mark the first time Gujarat has proposed a dedicated banking charge for Green Energy Open Access consumers. If notified as drafted, captive and third-party solar/wind consumers banking surplus generation with the grid would face a new cost that was not previously charged.

Note: This page summarises the mechanism and direction of GERC’s draft regulation for reference purposes. Exact charge percentages, effective dates and grandfathering provisions should be confirmed against the final notified regulation before being relied upon for financial modelling.

What is banking, in Gujarat?

Gujarat’s Open Access framework has historically allowed GEOA consumers to bank surplus renewable generation with the DISCOM and draw down an equivalent quantum later in the billing cycle, without a dedicated charge for the service itself — banked energy was adjusted against consumption largely on a like-for-like basis. GERC’s draft regulation proposes to formalise banking as a chargeable grid service for the first time, bringing Gujarat in line with several other states that already levy a banking charge.

Important rules & conditions (as proposed in the draft)

  • A banking charge is introduced as a percentage-based deduction on banked units — the exact quantum is to be confirmed on final notification.
  • The banking period is proposed to align with the existing settlement cycle already used for other Open Access charges.
  • The draft signals closer alignment between the time-of-day (TOD) slot in which energy is banked and the slot in which it can be withdrawn.
  • Whether the charge applies to existing captive/group-captive consumers with live PPAs, or only prospectively to new connections, remains one of the more contested points in the current consultation.

Advantages & limitations

Advantages

  • Reduces the effective cost mismatch between intermittent renewable generation and continuous industrial demand.
  • A formal, notified charge — once finalised — removes prior ambiguity for developers structuring long-term PPAs.
  • Aligns Gujarat’s framework with regulatory practice already established in several other states.

Limitations

  • Introduces a new cost that was not previously charged, directly affecting project IRR for existing GEOA consumers.
  • Draft status means final charge levels and effective date remain uncertain, complicating financial modelling.
  • TOD-linked withdrawal restrictions, if finalised, could reduce flexibility for consumers with variable load profiles.

Comparative context

Gujarat is proposing to move from a no-charge banking model to a charged one. Other major Open Access states have already been charging a banking fee for several years. For a general comparison of how banking is structured across states, see Banking (Open Access).

Sources & references

  • GERC’s Draft Banking Charge – Regulations for Green Energy Open Access, Gujarat Electricity Regulatory Commission (consultation stage; not yet notified).

Frequently asked questions

Is the Gujarat banking charge already in effect?
No. As of this page, GERC's Banking Charge Regulations remain in draft form and have not been notified into force. Consumers should continue to follow the currently notified framework until GERC issues a final order.
Will the charge apply to my existing GEOA connection?
This is one of the more actively debated provisions of the draft. Whether the charge applies prospectively to new connections only, or to existing live PPAs, is not yet settled — check GERC's final notification before assuming either treatment.
How does this compare to other states?
See Banking (Open Access) for a general comparison of how banking charges are structured elsewhere in India.
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