What a banked renewable unit is worth, and when the right to it ends

India Renewable Banking Index · Karnataka, Gujarat and Andhra Pradesh · FY 2026-27

Banking is the least examined number in an open-access project. This report puts a rupee figure on a banked unit in three states, built only from the tariff orders, regulations and judgments that produce it — and sets out when the right to bank ends, which turns out to be a different question in each of them.

Banking is the least examined number in an open-access project. Tariffs are argued over, wheeling charges are modelled, cross-subsidy surcharge gets a line in every term sheet. Banking usually gets a sentence: "banking available, 8% in kind." That sentence hides most of what matters.

This report does two things. It puts a rupee figure on a banked unit in three states, built only from the tariff orders and regulations that produce it. And it sets out when the right to bank ends, which turns out to be a different question in each of the three, and a harder one than the price.

Nothing here is behind a paywall. Every figure can be traced to a signed document, and where a document is ambiguous I have said so rather than picked a reading.

The table

These are pre-open-access-charge marginal banking values. They are net of the stated banking charge, but before cash wheeling and transmission charges, cross-subsidy surcharge, additional surcharge, and voltage-specific in-kind wheeling losses. They are not landed costs and should not be compared with a PPA tariff.

All rows are FY 2026-27. Regulatory position reviewed as at 13 September 2026. The six rows are not a normalised ranking: they differ by route, tariff category and drawal condition, and the Andhra rows exclude the fuel adjustment that the Karnataka and Gujarat rows include (Limitations 1 and 4). "Current cohort" means projects governed by the Open Access Regulations, 2025 rather than by the legacy wheeling-and-banking arrangements discussed in the seventh finding.

Karnataka: energy 660 p, plus pension and gratuity surcharge 35 p, plus the June 2026 fuel adjustment of 2 p, less the 8% in-kind banking charge. The 09:00–18:00 slot carries a nil time-of-day adjustment in both seasons. The fuel adjustment is a monthly, formula-driven component and it changes sign: on the July 2026 adjustment of −23 paise the same row is ₹6.18. The row states the month it uses, and a reader pricing a year should not treat a single month's adjustment as a settled annual figure.

Gujarat: energy 420 p plus the directed FY 2026-27 base fuel and power purchase price adjustment of 245 p, less the ₹1.00/kWh banking charge. That charge changed inside the year. It was ₹1.50 until 31 August 2026 and became ₹1.00 on 1 September 2026 under the Sixth Amendment to the Green Energy Open Access Regulations, gazetted on 19 August 2026. The same reference consumer was therefore at ₹5.15 for the first five months of the year.

Andhra Pradesh: the ₹5.55 is the tariff alone. Andhra recovers its fuel and power purchase cost adjustment outside the tariff schedule, capped at 40 paise a unit a month with the balance carried to a true-up. The Karnataka and Gujarat rows include their fuel adjustment; the Andhra rows do not. Read across the three states with that in mind.

Andhra Pradesh: both rows sit on the same off-peak tariff of ₹5.55/kWh. Row 5 retains 92 per cent of it and row 6 retains 98 per cent, but the two charges are levied on different quantities — 8 per cent of energy banked at the consumer end, against 2 per cent of energy delivered at the point of drawal. The multipliers are not a like-for-like comparison of banking charges, and the identical base is used here only to isolate the retained-energy effect. It says nothing about the two cohorts' availability, drawal restrictions or expiry risk, which differ sharply and are dealt with below.

Voltage is stated only where the source states it. No voltage equivalence is assumed across the three states.

A note for readers of Report No. 1. That brief valued a banked unit at ₹5.54 for a night-load consumer. This is not a revision of it. That figure is a twelve-month average across both of Karnataka's tariff seasons for the 22:00–06:00 slot, and it excludes the pension surcharge and the fuel adjustment. Row 1 above is a single slot in a single month with both included. Put on the basis used here, the Report No. 1 night figure becomes ₹5.88. The two answer different questions and neither replaces the other.

Reference tariff and charge basis: FY 2026-27, to 31 March 2027. Banking entitlement horizons differ by state and are dealt with separately.

1. The first question is not which state. It is which route.

Before asking where banking is worth most, ask whether the project will be captive or third-party. The answer moves the number further than the choice of state does.

Take the Karnataka row all the way down.

The 2.76 per cent is applied as a physical deduction from the reference quantity; the 29 paise and the ₹1.86 are then taken as cash deductions. That order follows Karnataka's own mechanism of deducting losses from net injected energy, and it has been verified for Karnataka only. It is not a universal sequencing rule.

This is a wheeled open-access reference, not a behind-the-meter rooftop value. It carries both the in-kind loss and the cash wheeling charge, and the captive row assumes cross-subsidy surcharge does not apply, which depends on captive eligibility being properly established and maintained. The ₹6.41 and the ₹5.94 are stages of one case, not competing numbers.

In Karnataka the two route-specific charges now come to ₹2.26 — cross-subsidy surcharge of ₹1.86 plus an additional surcharge of 40 paise that the Commission has expressly made inapplicable to captive consumption. Cross-subsidy surcharge alone is ₹1.86 in Andhra Pradesh and ₹1.33 in DGVCL. The spread across the three states' reference rows is of the order of a rupee — and less than that once the Andhra row is put on the same fuel-adjustment footing as the other two. The route costs more than the geography, and the gap between the two comparisons is widening rather than narrowing.

Additional surcharge is no longer nil, and the way it arrived matters as much as the amount. The tariff order of March 2025 recorded that it would not be levied until BESCOM petitioned and the Commission ordered. BESCOM petitioned in August 2025 in OP No. 29 of 2025, asking for 58 paise a unit on a stranded capacity of 1,033 MW. Twenty-one open-access consumers and industry bodies objected. The Commission cut the allowed fixed cost, recomputed net stranded charges at ₹247.61 crore against open-access sales of 6,248 million units, and approved 40 paise. It refused a retrospective levy and made the charge run prospectively from March 2026, across the ESCOM jurisdictions and consumer classes named in its operative directions, until the surcharge for the following year is settled, against which it is to be adjusted. It does not apply to energy drawn for captive consumption, nor to supply from non-fossil waste-to-energy plants. The order is itself subject to the High Court proceedings on the Open Access Regulations, 2025.

Two things follow. The first is the figure in the ladder above. The second is that the Commission has directed BESCOM to file for the next year so that a revised surcharge can be levied from July 2026, so the 40 paise is an interim number within the reference year of this report and is expected to be replaced. It is used here as the latest verified order-based figure, not as a claim that it held unchanged through FY 2026-27. Any later annual determination should displace it from that determination's own effective date.

2. Three states, three ways for the right to end

Karnataka is on a clock. Clause 12.e(i) of the Open Access Regulations, 2025 grants banking for five years from the effective date of each wheeling-and-banking agreement, so the entitlement rolls forward as agreements are renewed. Draft Regulation 39.1 of the Connectivity and General Network Access Regulations, 2026, published by the Commission for consultation, would replace that with one fixed date for everybody: 31 March 2030. A consumer signing in 2027 would lose banking in 2030 instead of 2032. The draft is not in force and is not used as a current-law input here. No final notification replacing the draft was located in the Commission's public materials reviewed as at 13 September 2026.

A second limb of clause 12.e(i) already bites. An agreement predating 13 January 2023 for short-term access, or 2 January 2023 for long-term, becomes ineligible for banking if renewal is sought.

Andhra Pradesh is protected. Clause 22(d) of Regulation 3 of 2024 protects agreements made under that regulation, including banking, its period and the waivers, against future regulations and amendments, for the term of the agreement or the Policy Period, whichever is longer. This is the mirror image of a sunset, and it is the kind of clause a lender can actually price.

Gujarat has no identified end date, and an annual price. No general expiry for the banking facility has been found in the provisions of the Green Energy Open Access Regulations, 2024 reviewed here. What is dated is the charge. From FY 2027-28 the banking charge is determined annually as ANB divided by TBE on fifteen-minute block data, and is deemed nil for a licensee that has not supplied the required data, until it does. The Commission may consider limiting its variation within a floor of ₹0.50 and a ceiling of ₹1.50, but only where the licensee has supplied complete, accurate and sufficient data; that is a power the Commission may exercise, not a fixed band. If the charge is not determined in time, the Commission may by separate order continue the existing one. The entitlement carries no identified end date; its price is reopened every year, within a band the Commission may, but need not, apply.

Against a fifteen-year debt tenor these are three different animals: a termination date, a contractual protection, and an annual repricing. None of the three is visible in a rupee figure.

Why the instrument matters more than the rule

In 2018 the Karnataka Commission curtailed banking by order. The Appellate Tribunal set that order aside, applying PTC India Ltd v. CERC: the terms of concluded agreements lie beyond the reach of an order. They may be altered by regulations, prospectively. The Commission had instead reopened a matter it had already decided and on which it had become functus officio.

The restriction did not disappear. It came back in 2025, inside the Open Access Regulations, where, being a regulation and prospective, it holds. What changed between 2018 and 2025 was not the policy but the instrument. The cohort cut-off dates in clause 12.e(i) are the residue of that change.

The Tribunal's final position on that point, after the August 2019 correction, was firmer than the judgment alone suggests: the terms of a banking arrangement in a concluded contract cannot be modified, and a modification can operate only on future contracts.

The model regulation shows what a lawful version of the 2018 attempt looks like. Its repeal and savings clause preserves existing open-access agreements: a consumer or generator availing access under an existing contract when the new regulations commence is entitled to continue on the same terms. Banking is then carved out of that protection. The proviso makes the Commission's distribution open-access provisions on banking of power — along with the definition of billing demand and revision of contract demand — applicable to existing users as well.

That is the whole mechanism in one sentence. Grandfather the contract; do not grandfather the banking. It is exactly what the Commission could not achieve by order in 2018, and it becomes available the moment the same restriction is placed inside a regulation with a savings clause drawn this way. Anyone relying on a pre-2023 Karnataka agreement should read that clause in whatever Karnataka finally notifies before assuming the agreement carries its banking terms with it.

The Tribunal was careful about what it did not say. It accepted that the Commission may alter the terms of an executed agreement — the agreements themselves provide for it at clause 13.6 or 12.6 — but only on the application of one of the parties and after hearing both. What it rejected was a suo motu modification by order. The protection is not that the agreement is untouchable. It is that a specific route must be taken to touch it.

So the question for anyone pricing a banking entitlement is not only what a state allows, but by what instrument, and whether that instrument reaches a contract already signed. A tariff order can be revised every year. A regulation binds going forward. An executed agreement can be reopened, but through a hearing rather than a stroke of the pen. Only the third protection is invisible in a rupee figure, and it is often the most valuable.

This report identifies regulatory and contractual risk mechanisms. It is not a legal opinion on the enforceability of any particular agreement.

3. The premium arrives before the surplus does

In their stated reference periods, all three frameworks put a higher value on energy banked in the morning peak.

The premium is real. Whether it can be collected is a different matter. A solar plant does generate between six and nine in the morning; the question is whether it generates more than the site is drawing in that fifteen-minute interval, because only the excess can be banked. That is the hour when output is still climbing and industrial load is climbing faster. A tariff table tells you what a banked unit is worth at that hour. Only a load curve tells you whether there will be one.

Underneath sits an asymmetry common to all three frameworks. Energy banked in a peak slot may be drawn in peak or off-peak. Energy banked in an off-peak slot may be drawn only in off-peak. Gujarat's Sixth Amendment, gazetted on 19 August 2026, puts it in as many words: net surplus energy banked in off-peak periods shall not be permitted for utilisation during peak periods, while energy banked in peak may be used in both. It is not a recent invention: in 2019, arguing before the Tribunal, the Karnataka Commission's own counsel pointed to Maharashtra, Andhra Pradesh and Telangana as states where banking was already available on a peak-to-peak basis, stricter than Karnataka's own.

It is worth being clear about where the rule does not come from. The Forum of Regulators' model State Connectivity and GNA Regulations of January 2026 deal with banking in three sub-clauses of Regulation 39. Surplus energy from a non-firm renewable station, after set-off, is banked with the distribution licensee; the banking charge is adjusted in kind at 8 per cent of the energy banked, or as the State Commission specifies; everything else is left to the State Commission's own regulations and orders. There is no slot rule in the model, no restriction on the hour of drawal, and no asymmetry between peak-banked and off-peak-banked energy.

So the 8 per cent that Karnataka and Andhra Pradesh both charge is the national default. The restriction that actually determines what a banked unit is worth is not. Each state wrote that for itself, and a state adopting the model will carry its own slot rule across rather than inherit one.

The model does segment time, but a layer earlier. It defines solar and non-solar hours by weekly declaration from the national despatch centre and ties injection scheduling rights to them, so a solar generator's right to inject is hour-bounded before any banking question arises.

Maharashtra has since reached the same place by a different road, and gone further. Deciding MSEDCL's review on 25 March 2026 in post-remand proceedings, the Commission held that its earlier ruling was inconsistent with Regulation 20.3 of the Distribution Open Access Regulations, 2016 and was an error apparent on the face of the record. It then set out the rule slot by slot. Energy banked in the normal slots, midnight to six and six to nine, may be drawn in the same slots and in solar hours, but not in peak. Energy banked in solar hours, nine to five, may be drawn only in solar hours. Energy banked in peak hours, five to midnight, may be drawn anywhere.

Read that middle line again. A solar plant banks in solar hours and may take it back only in solar hours — which is to say, in the hours it is already generating. For a daytime solar consumer that is not a restriction on banking so much as the end of it. The same rule applies to net metering and net billing under time-of-day, with residential rooftop exempted.

The ruling takes effect from 1 July 2025, nine months before the order, and MSEDCL has been directed to let affected consumers pay the difference in instalments. Other distribution licensees in the state have been given liberty to seek the same correction in their own tariff orders. State policy points the other way: the Renewable Energy and Energy Storage Policy notified a week before the order contemplates consumers above 100 kW banking across slots at a charge. The order has been challenged. Reported accounts of the appellate proceedings, not confirmed from an official docket, record an interim order of 27 April 2026 staying the revised banking dispensation and the invoices issued under it, restraining coercive recovery, and requiring charges to continue on the earlier basis against an undertaking, until final judgment. No final judgment was located as at 13 September 2026. This section therefore describes what the Commission decided, not what is currently billed.

What is being argued in Maharashtra is the same question this report's Karnataka section turns on, and on the same authority. Before the Commission, the licensee's case was that Regulation 20.3 permits adjustment from a higher-tariff slot to a lower one and not the reverse, and that any other reading would turn off-peak banking into risk-free arbitrage. The objectors' case was that the regulation's illustration cannot override its text, that a change of this kind requires a regulation and not a review petition, and — citing the Tribunal's judgment in Fortune Five Hydel v. KERC — that banking arrangements cannot be altered abruptly unless public interest demands it, with expectations managed gradually after agreements expire. A judgment delivered in 2019 about Karnataka is doing work in a 2026 Maharashtra tariff proceeding, which is a fair measure of how little settled law there is in this area.

Maharashtra is mentioned here and not in the table for that reason. The asymmetry can arrive through more than one legal route, but a state whose position is under appellate challenge cannot carry a reference row.

Whether a developer should build east-facing capacity to reach the morning block does not follow from any of this. The premium is documented. The surplus at that hour is not.

4. The retail tariff route can cost more than the banking rules do

A consumer picking a tariff is not thinking about banking. The choice decides the answer anyway.

Karnataka's Revised Discounted Energy Rate Scheme charges a flat ₹5.00 per unit above a base level, with no fuel adjustment on that block and, after the corrigendum of 26 May 2025, no time-of-day adjustment either. It is a perfectly rational retail choice. It also removes the evening premium and takes more than a quarter off the value of a banked unit.

Gujarat's HTP-IV is sharper. The energy charge is low, but the real effect is what the tariff forbids: consumption is confined to 22:00–06:00. A solar consumer on HTP-IV self-consumes almost nothing during generating hours and has to push the entire output through a banking facility that is itself quantum-bounded. Before valuing a banked unit under any concessional tariff, read what the tariff prohibits, not only what it charges.

5. The billing base decides which charges a banked unit escapes

Whether a per-unit charge attaches to wheeled and banked energy is not answered by the banking regulation. It is answered by the billing base, and that is set out in places nobody thinks to look.

Karnataka's HT tariff schedule excludes wheeled energy from the high-voltage rebate. That is direct evidence that wheeled units are billed separately for at least one component. It does not follow that every surcharge behaves the same way, and I have not extended it.

In Gujarat the answer to "what does the surcharge multiply?" is in neither the tariff schedule nor the banking regulation, but in one sentence of the fuel price adjustment computation directions: it applies to the energy charge, the base adjustment and the fixed or demand charge. PGVCL's reply to objection 62, refusing a power-factor rebate on a similar footing, states the same incidence principle in terms.

There is a third observation which I record with a caveat attached. Two BESCOM HT-2(a) bills reconcile to the rupee only if the fuel adjustment and the pension surcharge are billed on metered consumption less wheeled energy — a treatment that appears in no regulation, tariff order or computation workbook. The arithmetic is unambiguous. The provenance is not: these are copies obtained from a public document-sharing site, not from the licensee, and I have not been able to verify the issuing period or that they are unaltered. Two bills are in any case one consumer in one period. Treat it as a lead worth testing against a bill whose origin you can vouch for, not as a finding. No bill image, consumer name, account or connection number, address, location or consumption history is reproduced here.

For a developer this is the difference between a charge avoided and a charge payable on every unit for the life of the project.

6. In Karnataka, banking and the discount scheme compete for the same unit

Section 6.14 B(a) of the Combined Tariff Order-2025 computes the discount scheme's base on energy taken from the ESCOMs only. Energy sourced through open access or wheeling is expressly excluded. The two schemes therefore bid for the same marginal unit from opposite directions.

A consumer may use both mechanisms in the same billing period, but cannot count the same marginal unit twice. Every banked unit drawn reduces ESCOM consumption and pushes the consumer back toward the base, where the discount is lost. Every unit taken under the discount scheme is a unit that banked energy did not displace. The instruments reviewed here do not say how a consumer is expected to resolve that.

The pension and gratuity treatment used here is no longer an assumption. The amending order of 27 March 2025 recovers the surcharge on a per-unit consumption basis expressly excluding consumption under the scheme. What remains open is the reach of that phrase: whether it means only the discounted block above the base, or the consumer's entire consumption. Either reading leaves the ₹4.60 undisturbed, but they are not the same rule.

7. A lower banking charge does not settle the question

Two of the three states run two banking regimes side by side, and in both the older regime charges less. That tells you very little. In Andhra Pradesh the cheaper cohort is demonstrably the worse deal. In Karnataka the cheaper cohort's terms are settled for now, but expressly provisional.

Andhra Pradesh. The legacy code charges 2 per cent in kind against the current regime's 8 per cent. On the same ₹5.55 off-peak tariff that is ₹5.44 against ₹5.11, so the cheaper cohort looks to be worth 33 paise more.

It is not. The legacy cohort may not draw banked energy at all between 1 April and 30 June, or between 1 February and 31 March. Five months of every year. It may not draw in peak hours at any time. Its banking year is annual, and whatever is unutilised on 31 January is deemed purchased by the licensee at half the pooled cost of power purchase. Price is one lever. Timing is the other, and here it is much the bigger one.

Karnataka: a right that survived, and what it is hanging on

Projects that applied for open access before 13 January 2023 for short-term access, or 2 January 2023 for long-term, sit outside the 2025 Regulations, with annual banking at 2 per cent of energy injected. What governs that cohort today is settled but expressly provisional, and the reason is worth setting out in full.

On 9 January 2018 the Commission reduced banking from one year to six months and confined peak-hour drawal to energy banked in peak hours. On 29 March 2019, in Appeal No. 42 of 2018 and batch, the Appellate Tribunal set that order aside in its entirety. It found no supervening public interest; that solar generators had never been given notice even though the operative part of the order reached them; that promissory estoppel and legitimate expectation had been breached, the agreements having guaranteed annual banking for ten years; and that neither the petitions nor the order contained data or analysis of the financial injury on either side. The Commission had also, on the Tribunal's reading, revisited a question it had already decided in 2013 and 2014.

The judgment as pronounced did not stop at quashing. It sent the matter back to the Commission to pass a fresh order within six months. That direction did not survive. On the generators' application in the same appeal, the Tribunal by an order of 5 August 2019 deleted the remanding paragraph from the operative part altogether, holding that modification of the terms and conditions of a banking arrangement in concluded contracts is bad in law, and that such modification could be applied to future contracts. There was therefore nothing left for the Commission to reconsider.

On 27 July 2019 the five ESCOMs appealed to the Supreme Court. The appeals were admitted on 17 December 2019 with notice issued on the prayer for interim relief. On 27 February 2020 the Court directed counter affidavits from two respondents, permitted service on those not yet served, and listed the matter for 24 March 2020. The public docket records admission on 17 December 2019 and the directions on service and counter affidavits on 27 February 2020. No later substantive order was located in the public record as checked on 13 September 2026. Interim relief was sought; no order granting it was found.

What governs the cohort in the meantime is settled, and the Commission has said so itself — though not in one piece, and not on the same terms for everyone in it.

By an interim order of 7 September 2021 the Commission continued existing wheeling and banking charges and the annual banking facility, and it divided the cohort by commissioning date. Projects commissioned on or before 31 March 2018 that had entered into an agreement were continued "for the present", the Commission noting that neither the High Court's Division Bench nor the Supreme Court had stayed the orders in its favour. Projects commissioned after that date were continued only until 31 March 2022, and only against a written undertaking from the generator that it would abide by whatever those two courts eventually decide.

The later group's benefit was therefore both time-bound and expressly conditional on accepting the risk of the litigation outcome. This report has not inspected any executed undertaking; what the order establishes is that the Commission made one a condition of the interim arrangement.

The background to that order is also worth recording. In August 2020 the Commission had circulated a discussion paper proposing to halve wheeling concessions and to discontinue banking for solar, mini-hydel and wind altogether, with energy unused at the end of each month deemed supplied to the ESCOM free of cost. It did not proceed. By 2021 agreements were not being processed at all for want of clarity, which is what prompted the interim order. By its order of 7 August 2023 on wheeling charges and banking for renewable projects, having recited that history, it decided to continue annual banking and a banking charge of 2 per cent of injected energy for Non-REC projects that applied for a wheeling-and-banking agreement between 1 April 2018 and the green open-access cut-off — expressly subject to the final decision of the pending Supreme Court case. The Commission's order of August 2023 records that the September 2021 interim arrangement continues until the Division Bench disposes of the separate proceedings on wheeling charges. And by a letter of 30 March 2023 the Commission told the transmission utility and the ESCOMs that wherever an agreement had already been executed with a six-month banking period, it was to be read as annual banking.

So the entitlement is real, written down and currently honoured. It is also expressly provisional. A lender looking at a pre-2023 Karnataka project is not looking at a right that might not exist; it is looking at a right that exists on the condition that an appeal last listed in February 2020 is never decided the other way. Those are different risks and they price differently.

Who is in that batch is as telling as the rule. The respondents include the Commission and the transmission utility themselves, wind, solar and small-hydro generators, and large industrial users: an aluminium producer, a graphite manufacturer, an arecanut marketing federation, a gases company, a hatchery. This is not a class of developers. It is a mixed group of generators and captive consumers, held together by nothing except the date on which they signed.

A note on the 2 per cent that disappeared

The Commission's own worked example is the clearest record of how Karnataka banking is calculated, and of what has changed.

The methodology notification of 10 January 2024 works through three days of settlement: total injection 1,315 kWh, total drawal 1,295 kWh, net banking 20 kWh. Its Table-2 adds the slot-wise and day-wise banked quantities to 135 kWh and charges 8 per cent in kind, 10.80 kWh. Then it takes one more step. Of the 40 kWh banked in off-peak, 20 kWh is treated as drawn in peak by set-off against the month's net peak drawal, and a further 2 per cent is charged on that set-off quantity: 0.4 kWh. Total banking charge, 11.20 kWh.

The Commission had explained the reasoning in its order of 8 June 2023. The Green Energy Open Access Rules were silent on an extra charge for drawing off-peak energy during peak hours, so, consistent with the methodology developed by the Forum of Regulators, it decided that 2 per cent in kind should be charged in addition to the 8 per cent.

Draft Regulation 39.5 of the 2026 regulations reproduces the same example. Same three days, same quantities, same table. It stops at 10.80 kWh. The last operation is gone, as it is from the worked example in clause 12.e(iv) of the 2025 Regulations.

What the documents show is that an example was carried forward with its final step removed. Whether the 2024 methodology notification continues to operate alongside the later regulations is a separate question, and this report does not answer it.

Limitations

1. Reference condition. Each row is conditional on the named utility, tariff category, banking cohort, tariff route, drawal condition and tariff year. Change any one of them and the figure changes.

2. Cash charges and physical losses. The six-row table is stated before all open-access charges. The Karnataka ladder deducts the verified 2.76 per cent in-kind wheeling loss and the 29-paise cash wheeling charge. Gujarat and Andhra Pradesh are not shown on the same basis, because the order in which an in-kind loss and a cash charge apply has been verified from the primary record for Karnataka alone.

3. Gujarat quantum. The 30 per cent is both, at different levels, and the report uses it as a cap. The Ministry of Power's green open-access rules require states to permit banking of at least 30 per cent of a consumer's monthly consumption from the licensee — a floor on the state's obligation. Gujarat's regulation caps cumulative banking at any point at 30 per cent of that consumption in the billing cycle — a ceiling on the consumer. What remains open is whether the stated 60-paise rebate is given in practice.

4. Andhra fuel adjustment. The Andhra rows are stated before fuel and power purchase cost adjustment, which that state recovers outside the tariff schedule. The Karnataka and Gujarat rows include theirs. Cross-state comparison of the six rows is therefore indicative, not normalised.

5. Dates and pending instruments. 31 March 2027 is the reference date for the FY 2026-27 tariff and charge inputs. It is not the expiry date of any entitlement. Three matters could move the picture and none is decided: the Supreme Court proceedings on Karnataka's legacy cohort, in which no later substantive public order was located as at 13 September 2026; the judicial challenge to Maharashtra's revised banking dispensation, which is reported to be under an interim order of 27 April 2026 staying the revised dispensation pending final judgment, the scope of that order not having been confirmed from an official docket as at 13 September 2026; and Karnataka's draft Connectivity and General Network Access Regulations, 2026, gazetted but not notified, which would replace the rolling five-year entitlement with a single end date of 31 March 2030.

Source register

Every figure in this report comes from one of the documents below. Where a document was read in part, or reached through a licensee's copy rather than the Commission's own file, that is stated.

How this was built

Every figure comes from a tariff order, a regulation, a commission order or a judgment, read directly. Where a commission's own arithmetic does not reconcile, I have said so and used the notified figure. Where a number could not be traced to a primary document, the cell is empty rather than filled with the nearest available estimate.

Corrections are welcome, and preferred with the document reference attached.

Version 1.1, 28 September 2026: section 2 now states that the Gujarat floor and ceiling from FY 2027-28 is a power the Commission may exercise, not a fixed band; two sentences in section 7 on Karnataka's legacy cohort were made consistent with that section's conclusion; a line was added under the table; one source-register row (KA-14) was moved into the register table. No figure changed.