The Central Electricity Regulatory Commission ("CERC") issued the CERC (Connectivity and General Network Access to the Inter-State Transmission System) Regulations, 2022 on June 7, 2022 ("GNA Regulations"), with the objective of enabling non-discriminatory open access to the inter-State transmission system ("ISTS") for generating companies through the general network access ("GNA") framework. The GNA Regulations were subsequently amended on April 1, 2023 and June 19, 2024.
On August 31, 2025, the CERC issued the third amendment to the GNA Regulations ("Third Amendment"), introducing significant changes to the procedures involved in the grant of connectivity, its withdrawal and relinquishment, the key conditions for grant of connectivity and GNA, change of control restrictions, etc.
It is important to note that prior to the introduction of the Third Amendment, the CERC had issued two separate drafts of amendments to the GNA Regulations – the draft third amendment issued on July 31, 2024, and the draft fourth amendment on March 3, 2025 (collectively, referred to as the "Draft Amendments").
The Third Amendment has been issued after taking into consideration the changes discussed in both the Draft Amendments.
Key Highlights –
We have analysed the key amendments to the GNA Regulations introduced through the Third Amendment, and its consequent implications, which have been set out below:
A. Withdrawal of Connectivity Applications –
The Third Amendment sets out the following consequences on the applicant based on the stage at which the application for grant of connectivity or GNA has been withdrawn:
| Stages for Withdrawal | Consequences |
| Before grant of in-principle connectivity for full quantum |
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| Before grant of in-principle connectivity for partial quantum (based on the non-availability of transmission capacity for the full quantum at the relevant connecting substation) |
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| After grant of in-principle connectivity but before grant of final connectivity |
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| After grant of final connectivity but before signing of connectivity agreement3 |
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In all cases of withdrawal as discussed above, the land documents are to be released in favour of the applicant within 15 (fifteen) days of such withdrawal.
B. Connectivity for Non-Solar Hours and Full Day Access –
The Third Amendment now allows renewable energy generating stations ("REGS") based on wind source or energy storage systems ("ESS") to seek connectivity based on "solar hour access"6 and "non-solar hour access"7. Accordingly, an REGS based on wind source (with or without storage) or ESS can seek connectivity with non-solar hour access for a quantum of 50MW (fifty megawatt) and above at terminal bay of an ISTS substation:
- through a separate dedicated transmission line; or
which is already allocated to another REGS or renewable power park, with solar access.
C. Connectivity for REGS with Storage and Standalone ESS –
Under the Third Amendment, in case of REGS with storage, the applicant is required to specify the maximum quantum of injection and maximum quantum of drawal requirement from the grid (for the purpose of charging power for storage) within the quantum of connectivity, based on the installed capacity of the REGS and storage.
In case of standalone ESS, an applicant is required to apply for the grant of connectivity for a quantum of its proposed maximum injection to ISTS or proposed maximum withdrawal, whichever is higher. An ESS, in its application, is required to indicate the maximum quantum of injection to ISTS and maximum quantum of drawal from ISTS.
These entities will be eligible to schedule power under such connectivity for the maximum quantum of injection and maximum quantum of drawal sought by such applicant and as indicated in the final grant of connectivity.
D. Grant of Connectivity as per the LOA or PPA –
The Third Amendment restricts the quantum for which connectivity can be sought by an REGS (other than hydro generating station or ESS (excluding pumped storage plant ("PSP")). In such cases, the applicant will be eligible to apply for connectivity upto the quantum for which the letter of award ("LOA") has been awarded or the power purchase agreement ("PPA") has been executed or the installed capacity provided in the LOA or PPA, whichever is lower. The connectivity for any additional capacity or balance capacity will have to be sought by evidencing land documents or submitting bank guarantees, as required, for which additional capacity.
In cases where the connectivity has been granted on the basis of the LOA, the connectivity grantee8 is required to furnish the copy of the PPA within 1 (one) week of its execution along with the scheduled commercial operation date ("SCOD") under such PPA.
E. Change in Control-
One of the key conditions introduced through the Third Amendment is the specific restriction on any change in control9 of the connectivity grantee, until the commissioning of the project. The Third Amendment specifically provides that in case the connectivity grantee is a single company, the promoters or shareholders are required retain control of the connectivity grantee; and in case the connectivity grantee is a consortium, the consortium members are collectively required to retain control of the consortium. This change in control restriction will apply from the date of connectivity application upto the date of commissioning of the project and deviation from these restrictions will require prior approval of the nodal agency10. The Third Amendment further provides that the failure to maintain the change in control in accordance with these restrictions will lead revocation of the connectivity granted as well as invocation of the bank guarantees submitted by the connectivity grantee.
Under the Third Amendment, REGS (other than hydro generating station or ESS (excluding PSPs) will also be required to provide the details of their promoters and the shareholding pattern of the company along with the tentative generation and drawal profile for the capacity for which connectivity is being sought.
F. Flexibility to Change Land Parcels –
The Third Amendment allows renewable energy developers to change the land parcels (party or fully) presented to the nodal agency at the application stage – a much need relief for renewable energy developers, at the implementation stage. In this context, the applicant is required to submit a formal request along with documents for new land parcels and identification of old land parcels which are sought to be replaced to ensure that the total land evidenced amounts to 50% (fifty percent) of the total land required for the project.
However, there can be no change in the point of connectivity and the start date of connectivity due to implementation of the renewable energy project at different land parcels.
G. No Requirement for Conn BG 2 –
The Third Amendment dispenses the requirement to provide Conn BG2 in case of the following: (i) the applicant proposes to construct the terminal bays on its own; (ii) the applicant seeks connectivity at a terminal bay which has been constructed or being constructed by another connectivity grantee; (iii) a distribution licensee or a bulk consumer seeking to connect to ISTS, directly with a load of 50MW (fifty megawatt) and above; (iv) an applicant seeks connectivity through electrical system or switchyard of a generating station.
H. Change of Sources –
The Third Amendment allows renewable energy developers to change the renewable energy source for which the in-principle connectivity or final connectivity has been granted. However, this change will be subject to the following conditions:
(a) the change in the renewable energy source must be for the same connectivity quantum;
(b) the application for such change must be submitted within 18 (eighteen) months from the in-principle grant of connectivity or 18 (eighteen) months prior to the effective date of the GNA, whichever is later;
(c) no change in the renewable energy source will be permitted if the requirement of 50% (fifty percent) land for the revised source exceeds the extent of land for which documents have been submitted;
(d) the change of source will be considered for entities with solar access only to the extent the non-solar access has not been granted to other entities;
(e) the change of source will be granted only once for a connectivity grantee.
The Third Amendment states that the nodal agency will subsequently also issue a detailed procedure prescribing the conditions to be fulfilled for allowing the change in the renewable energy source.
I. Start Date of Connectivity and SCOD –
The Third Amendment mandates that the intimation for final grant of connectivity is required to provide the start date of connectivity, either the tentative or firm date. If the tentative start date has been provided under the final grant of connectivity, then, the nodal agency is required to intimate the firm start date of connectivity in the following manner:
| Scenarios | Timeline for Intimation |
| Connectivity granted with augmentation (with ATS or without ATS) | Within 6 (six) months of final grant of connectivity, based on SCOD of ATS and terminal bay(s). |
| Coordinates of the ISTS
substation at which connectivity has been granted |
Final coordinate of the ISTS substation, along with the terminal bay location and single line diagram, within 6 (six) months of the issuance of the letter of award for the construction of such ISTS substation. |
The renewable power park developer is required to provide the SCOD of all the generation stations forming part of the power park within 3 (three) months from the date of intimation of firm start date of connectivity, failing which firm start date of connectivity will be considered as the SCOD.
J. Utilization of Connectivity by Subsidiaries –
The Third Amendment clarifies that any utilization of the connectivity by the subsidiary(ies) of the connectivity grantee or vice-versa will be allowed only at the connection point of ISTS at which the connectivity has been granted.
K. Relinquishment of Connectivity –
The Third Amendment sets out the following consequences on the connectivity grantee based on the stage at which the connectivity has been relinquished:
| Stages for Relinquishment | Consequences |
| Within 6 (six) months of the signing of the connectivity agreement |
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| After 6 (six) months of the signing of the connectivity agreement and before last date to furnish documents under Regulation 11A(1) of the GNA Regulations |
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Conclusion –
The Third Amendment has addressed few key renewable energy developer concerns such as flexibility in determining the source of renewable energy, change in land details, introduction of firm date for start of connectivity, etc., and has also introduced measures to aimed at maximizing the utilization of the inter-state transmission infrastructure and enhancing the overall efficiency of the grid. In its implementation, however, one of the key challenges will be to ensure certainty in the readiness and availability of the transmission infrastructure vis-à-vis the SCOD of the renewable energy projects and aide more efficient project planning for the renewable energy developers.
Footnotes
1 Land documents include registered title deeds as proof of ownership or lease rights or land use rights for 50% (fifty percent) of the land required for the capacity for which connectivity is sought by the applicant.
2 Conn BG1, Conn BG2 and Conn BG3 are the connectivity bank guarantees required to be submitted by the connectivity applicants under Regulation 8 of the GNA Regulations.
3 The Connectivity agreement is required to be executed between the nodal agency and the connectivity applicant, as per Regulation 10 of the GNA Regulations, after the final grant of connectivity to the applicant.
4 The GNA Regulations define the term "ATS" to mean "the ATS as determined in accordance with Regulation 6 of these regulations"
5 The GNA Regulations define the term "Terminal Bay" to mean "the bay at ISTS sub-station where dedicated transmission lines of a Connectivity grantee terminate"
6 The Third Amendment defines the term "solar access" to mean "access with injection scheduling rights during solar hours for the quantum of Connectivity and injection scheduling rights during non-solar hours for the capacity other than solar source limited to quantum of Connectivity and drawl rights throughout the day in accordance with Regulation 5.11 and Annexure- IV of these regulations"
7 The Third Amendment defines the term "non-solar access" to mean "access with injection scheduling rights during non-solar hours and drawl rights throughout the day in accordance with Regulation 5.11 and Annexure-IV of these regulations"
8 The Third Amendment defines the term "Connectivity Grantee" to mean "an entity which has been issued a final grant of Connectivity and has signed the Connection Agreement (Cat-1) under Regulation 10 of these regulations"
9 The Third Amendment states that the terms 'Promoter' and 'Control' will have the same meaning as defined under the Companies Act, 2013. In the case of a Connectivity Grantee where investment is made under the foreign direct investment route, the term 'Control' will have the same meaning as assigned under the Foreign Exchange Management Act, 1999, or the rules and regulations framed thereunder, including any notifications or circulars issued by the Reserve Bank of India.
10 The GNA Regulations define the term "nodal agency" to mean "(i) the agency designated for Connectivity or GNA to the ISTS, which shall be the Central Transmission Utility (CTU), for the purpose of Regulations 3 to 25 and Regulation 37 of these regulations; (ii) the agency designated for T-GNA for bilateral transactions which shall be RLDC of the region where point of drawal is located, for the purpose of Regulations 26 to 36 of these regulations; (iii) the agency designated for T-GNA for collective transactions which shall be NLDC, for the purpose of Regulations 26 to 36 of these regulations; (iv) the agency for implementation and operation of NOAR which shall be NLDC, for the purpose of Regulation 27 of these regulations"
Originally published on 08 September 2025
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
