GERC Draft Banking Charge Regulations — Green Energy Open Access Gujarat | GEOA.in
These are DRAFT regulations — not yet notified in the Official Gazette. All provisions are subject to change after stakeholder consultation.
📋 Regulatory Explainer · Gujarat · June 2026

GERC's Draft Banking Charge
Regulations for Green Energy Open Access

Two new draft amendments — the 5th and 6th — propose to extend the current ₹1.50/unit charge, then replace it with a scientifically determined rate from September 2026 onwards. Here's what it means for C&I consumers in Gujarat.

📄 5th Amendment Draft
📄 6th Amendment Draft
📅 Public Hearing: 21 July 2026
🏛 GERC, GIFT City, Gandhinagar

At a Glance

What GERC is Proposing

Until 31 Aug 2026
₹1.50/unit
Current banking charge extended via Draft 5th Amendment — bridging the gap while the new methodology is finalised
1 Sep 2026 – 31 Mar 2027
₹1.00/unit
Proposed interim rate under Draft 6th Amendment — based on study of 165 GEOA consumers (Apr 2025–Jan 2026), estimated actual cost ₹1.06/unit
From 1 Apr 2027 onwards
Data-based
Annual determination based on actual DISCOM data — with floor ₹0.50/unit and ceiling ₹1.50/unit to protect consumers and utilities

Section 01

What Is Banking and Why Does the Charge Matter?

Banking is one of the most commercially important features of Green Energy Open Access for C&I consumers in Gujarat.

Banking in plain language: When your solar or wind plant generates more power than you consume in a 15-minute slot, the surplus units are "banked" — virtually stored with the DISCOM. You can draw them back later when your consumption exceeds generation. This allows you to run a solar-heavy plant without worrying about slot-by-slot matching of generation and consumption.

The banking charge is what you pay the DISCOM for providing this service — it compensates the utility for the cost of managing the surplus energy on your behalf (holding it, potentially selling it on exchanges, and returning it when you need it).

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Why it matters to project economics

For a typical C&I GEOA project in Gujarat consuming 1 MU/month, the difference between ₹1.50/unit and ₹1.00/unit banking charge translates to approximately ₹4–6 lakhs per year in savings — depending on your banking utilisation rate. Accurate forecasting of this charge is critical to your open access savings calculation.

Key Banking Rules Under GERC GEOA Regulations 2024

ParameterRule
Banking periodOne calendar month (billing cycle) — no carry-forward to next month
Banking limitMaximum 30% of total monthly consumption from DISCOM in a billing cycle
Off-peak to peak useEnergy banked in off-peak slots cannot be drawn in peak slots
Peak to off-peak useEnergy banked in peak slots can be drawn in both peak and off-peak slots
Lapse ruleAny banked energy unused at month-end is deemed lapsed — no compensation
No-banking optionConsumers can opt out of banking; surplus then treated as inadvertent flow

Section 02

The ₹1.50 Journey — Six Extensions and Counting

GERC originally set the banking charge at ₹1.50/unit as an interim measure when GEOA regulations were first notified in February 2024. The rate has since been extended five times — and a sixth is now proposed.

Why has GERC kept extending?

Developing a scientifically sound banking charge methodology requires 15-minute slot-level data from all DISCOMs — DGVCL, MGVCL, PGVCL, UGVCL, Torrent Power, and smaller licensees. Collecting, validating, and analysing this data across a large and growing consumer base (165+ GEOA consumers tracked in the latest study) has taken longer than initially anticipated.

February 2024
Principal GEOA Regulations Notified Notified
GERC notifies GEOA Regulations 2024 (Notification No. 08/2024). Banking charge fixed at ₹1.50/unit, valid until 30 September 2024 pending a comprehensive study.
September 2024
1st Amendment — Extended to 31 March 2025 Notified
₹1.50/unit continued. Study still underway. Notification No. 16/2024.
March 2025
2nd Amendment — Extended to 30 September 2025 Notified
₹1.50/unit continued. Notification No. 06/2025.
September 2025
3rd Amendment — Extended to 31 March 2026 Notified
₹1.50/unit continued. Notification No. 08/2025. GERC acknowledges large-volume data collection is in progress.
March 2026
4th Amendment — Extended to 30 June 2026 Notified
₹1.50/unit continued. Notification No. 02/2026. Notified in Gujarat Gazette on 30 March 2026.
June 2026 — DRAFT
5th Amendment — Proposes Extension to 31 August 2026 Draft · Stakeholder Comments by 20 Jun
₹1.50/unit proposed to continue for two more months while the 6th Amendment methodology is finalised. Public hearing scheduled 22 June 2026.
June 2026 — DRAFT
6th Amendment — New Methodology + ₹1.00/unit from September 2026 Draft · Public Hearing 21 Jul 2026
Proposes ₹1.00/unit for Sep 2026–Mar 2027, then annual data-based determination from FY 2027-28 with floor ₹0.50 and ceiling ₹1.50. Full methodology in Annexure-I.
From April 2027 onwards
Annual Data-Based Determination Proposed
Banking charge determined each financial year based on actual DISCOM data for the preceding calendar year. Floor: ₹0.50/unit. Ceiling: ₹1.50/unit.

Section 03 · Draft 5th Amendment

Draft 5th Amendment — Bridging the Gap to 31 August 2026

DRAFT — Not Yet Notified

Stakeholder comments invited until 20 June 2026. Public hearing: 22 June 2026. Will come into force only upon publication in the Official Gujarat Gazette.

The Draft 5th Amendment is a straightforward bridging measure. With the 4th Amendment's ₹1.50/unit validity expiring on 30 June 2026, and the comprehensive 6th Amendment methodology still undergoing stakeholder consultation, GERC proposes a two-month extension to avoid a regulatory gap.

AspectDetail
Regulation amendedRegulation 1(4) and Regulation 17.6(viii) of GEOA Regulations 2024
What changesBanking charge of ₹1.50/unit extended until 31 August 2026 (or earlier if GERC notifies separately)
What does NOT changeAll other banking rules — limits, ToD slot restrictions, lapse rules — remain unchanged
Trigger to end earlyCommission retains right to notify a different charge before 31 August 2026 via separate notification
Stakeholder comments due20 June 2026
Public hearing22 June 2026 (hybrid mode)
What this means for you

No action needed. Your existing GEOA project economics for July–August 2026 remain unchanged at ₹1.50/unit banking charge. Focus your attention on the 6th Amendment, which makes the substantive change from September 2026 onwards.

Section 04 · Draft 6th Amendment

Draft 6th Amendment — The Big Change: New Rate + New Methodology

DRAFT — Not Yet Notified

Stakeholder comments invited until 20 July 2026. Public hearing: 21 July 2026, hybrid mode, GERC office at GIFT City, Gandhinagar. Will come into force only upon publication in the Official Gujarat Gazette.

Part A — The New Rates

PeriodProposed RateBasis
1 Sep 2026 – 31 Mar 2027₹1.00/unitBased on GERC study of 165 GEOA consumers (Apr 2025–Jan 2026). Estimated actual cost: ₹1.06/unit. Rounded down to ₹1.00 acknowledging data limitations and small sample size.
1 Apr 2027 onwardsData-based (annual)Determined each FY based on preceding calendar year data from DISCOMs. Floor: ₹0.50/unit. Ceiling: ₹1.50/unit.

Part B — Floor and Ceiling Mechanism (from FY 2027-28)

To provide regulatory certainty, GERC proposes bounding the annual determination within a range:

Floor: ₹0.50/unit

Banking charge cannot fall below ₹0.50/unit regardless of actual cost computation — protects DISCOM revenue adequacy.

Ceiling: ₹1.50/unit

Banking charge cannot exceed ₹1.50/unit — protects GEOA consumers from runaway charge increases.

Critical: The DISCOM Data Obligation

The floor-ceiling mechanism applies only if the DISCOM provides complete, accurate data via sworn affidavit in the specified format and timeline. If a DISCOM fails to provide adequate data, its banking charge is deemed Nil for that period — ensuring the consequence of non-compliance falls on the utility, not the consumer.

Part C — DISCOM-wise vs. Common Charge

The 6th Amendment gives GERC flexibility to determine either individual DISCOM rates or common rates for groups:

CategoryApproach
State DISCOMs (DGVCL, PGVCL, MGVCL, UGVCL)Commission may determine a common banking charge applicable to all four
Private licensees with common procurementCommission may apply a common charge
SEZ/SIR/Port DISCOMs and new licenseesCommission may apply the same charge as state DISCOMs
Torrent Power (private, independent)Individual determination based on Torrent's own data submission

Section 05

How Will the Banking Charge Be Calculated from FY 2027-28?

The 6th Amendment includes a detailed Annexure-I with the step-by-step methodology. Here's the plain-language version — the key insight is that the charge reflects the actual net cost to the DISCOM of providing banking.

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The Core Formula

Banking Charge (₹/unit) = Aggregate Net Banking Cost ÷ Total Banked Energy
The "net banking cost" is the DISCOM's cost of managing your banked energy (backing down thermal plants, buying/selling on IEX, using BESS) minus the revenue it earns from those activities. Divided by total energy banked — giving a per-unit charge.

1

Slot-wise Surplus/Drawl Computation

For each 15-minute slot, compute net surplus (generation > consumption) or net drawl (consumption > generation) for every GEOA consumer. Track cumulative banking separately for peak and off-peak periods on a FIFO basis.

2

Consolidation at DISCOM Level

Sum up all consumers' slot-wise surplus, drawl, banked energy, and lapsed energy across the billing cycle (calendar month) to get DISCOM-level totals for each 15-minute block.

3

Cost & Revenue Calculation per Slot

For each slot, compare IEX market clearing price against variable cost of marginal thermal stations. Based on which is cheaper, compute: cost to DISCOM (of buying from IEX or running thermal) and revenue earned (from selling surplus or saving generation). Four scenarios covered.

4

Aggregate Banking Charge for the Year

Sum all net banking costs across all 15-minute slots for the calendar year. Divide by total banked energy (excluding lapsed energy). The result is the banking charge in ₹/kWh for the next financial year.

Key Inputs Used in the Methodology

InputSourceWhy It Matters
IEX Market Clearing PriceReal-time (10.5%) + Day-ahead (89.5%) combinationDetermines whether DISCOM sells surplus on exchange or uses internally
Variable cost of marginal thermal stationGERC Tariff OrderBenchmark for DISCOM's internal generation cost
Backing down cost8% of total thermal cost (CEA Flexibilisation Report)Cost of reducing thermal output when surplus RE is available
BESS LCOEAverage of BESS bids (without VGF) from preceding yearCost of energy storage used by DISCOM to manage RE surplus
Transmission charges & lossesGERC Tariff Order, ISTS loss data from Grid ControllerAdjusts the effective cost of IEX transactions
Distribution lossesLatest GERC True-up Order per DISCOMNet injection = gross injection × (1 – loss%)

Section 06

What This Means for C&I Consumers in Gujarat

Impact on Project Economics

PeriodBanking ChargeChange vs. TodayIndicative Annual Impact*
Until 30 Jun 2026₹1.50/unit (current)Baseline
Jul–Aug 2026 (5th Amendment)₹1.50/unitNo changeNo change
Sep 2026–Mar 2027 (6th Amendment)₹1.00/unit (proposed)▼ ₹0.50/unit saving~₹5 lakhs/MW/year saving*
From Apr 2027 onwards₹0.50–₹1.50/unit (data-based)VariableDepends on DISCOM data

*Indicative only, based on ~10 MU/MW/year banking utilisation at ₹0.50/unit saving. Actual impact varies with your consumption profile, banking utilisation rate, and DISCOM.

Strategic Considerations

📉
Lower banking charge from Sep 2026 improves project IRR

If the 6th Amendment is notified as drafted, the ₹0.50/unit reduction in banking charge from September 2026 improves the savings per unit of RE consumed under GEOA. Projects currently being evaluated should model both scenarios — ₹1.50/unit (conservative) and ₹1.00/unit (optimistic) — until the amendment is officially notified.

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Floor-ceiling mechanism brings predictability from FY 2027-28

The ₹0.50–₹1.50/unit band means your maximum banking charge exposure is now capped. This makes long-term GEOA projects more bankable from a lender's perspective — the regulatory uncertainty around this charge is significantly reduced.

Do not revise project models until the regulation is notified

These are draft regulations undergoing stakeholder consultation. The final notified charge may differ from the draft. Continue using ₹1.50/unit for project appraisals until official gazette notification.

ToD Banking Rules — Unchanged but Important to Re-review

The new amendments do not change the existing ToD banking slot restrictions. These remain a key commercial consideration:

Solar generation periodCan bank inCan draw back in
Off-peak slots (daytime solar hours)Off-peak banking poolOff-peak slots only — cannot use in peak slots
Peak slots (if any generation)Peak banking poolBoth peak and off-peak slots
End of month surplusLapses — no compensation, no carry-forward

Section 07

Frequently Asked Questions

Will the ₹1.00/unit rate apply automatically from 1 September 2026?
No. The 6th Amendment is still a draft. It will apply only after it is officially notified in the Gujarat Government Gazette. Until then, ₹1.50/unit remains applicable (and the 5th Amendment proposes extending this to 31 August 2026). Monitor the GERC website (gercin.org) for the final notification.
Can I participate in the public hearing on the 6th Amendment?
Yes. The public hearing is scheduled for 21 July 2026 at GERC's office in GIFT City, Gandhinagar, in hybrid mode. Written comments and objections can be submitted before 20 July 2026. As a C&I GEOA consumer or prospective consumer, you have standing to participate and submit your views.
What if my DISCOM (e.g., Torrent Power) does not submit data to GERC?
The draft 6th Amendment has a specific provision for this: if a Distribution Licensee fails to provide complete and accurate data in the specified format and timelines, the banking charge for that licensee is deemed Nil until satisfactory data is submitted. This is a strong incentive for DISCOMs to comply. However, a "Nil" charge period may subsequently be revised once data is submitted.
Does the new methodology change the 30% monthly banking limit?
No. The 30% monthly consumption cap on banking remains unchanged. The 6th Amendment only changes the charge computation methodology — not the operational rules for how much you can bank or when you can draw.
How does the banking charge affect my GEOA savings calculation?
Banking charge is a deduction from your gross RE savings. The savings formula is: RE Savings = (Variable Grid Tariff + ED) − PPA Price − CSS − Wheeling Charges − Wheeling Losses − Banking Charge. A lower banking charge directly increases your net savings per unit.
Is the ₹1.00/unit rate applicable to Torrent Power consumers in Ahmedabad?
Torrent Power is a private licensee with independent data. The 6th Amendment gives GERC flexibility to set a common rate for state DISCOMs but Torrent's rate will depend on its own data submission and GERC's determination. The interim ₹1.00/unit is the proposed rate pending data-based determination — Torrent Power consumers should track this separately.
What happens to banked energy at year-end under the new regulation?
Nothing changes here. Banking is monthly, not annual. Surplus at month-end lapses — this rule is unchanged. The "year-end" concept only applies to GNM/VNM surplus energy settlement under Net Metering regulations, not to GEOA banking.

Public Hearing · 6th Amendment

Your Voice Matters — Submit Comments Before 20 July 2026

GERC has invited comments, suggestions, and objections from all stakeholders on the Draft 6th Amendment. This is your opportunity to shape how banking charges are determined for the next several years.

Comments Due
20 July 2026
Public Hearing Date
21 July 2026
Venue
GERC, GIFT City, Gandhinagar (Hybrid)
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