Rajasthan Mandates Battery Energy Storage for Green Open Access Projects of Size >5MW
In May 2025, Rajasthan became the latest state to adopt Central Green Open Access (OA) Rules, 2022. Rajasthan’s GEOA rules are meticulous and have enhanced the upper limit of renewable energy (RE) plant size to twice the contract demand for all captive OA projects. Additionally, Rajasthan’s GEOA rules are the first to mandate the inclusion of battery energy storage systems (BESS) as a critical component of open access projects.
For any green OA plant with a capacity greater than 5 MW, developers must establish a BESS with a minimum storage duration of 2 hours, which must be equivalent to 5% of the plant’s capacity. BESS is also mandatory for captive OA plants that exceed the consumer’s contract demand.
Table: Salient features of the Rajasthan GEOA Rules, 2025
Source: RERC, JMK Research
In addition to the regulatory mandate, the Rajasthan GEOA rules also furnish detailed exemptions for transmission and wheeling charges to BESS projects. These exemptions offer a 75% reduction in transmission and wheeling charges for OA projects that install BESS equivalent to 5% of their RE plant capacity. This exemption increases to 100% when the BESS capacity reaches 30%. However, these exemptions apply only to the first 2000 MW of battery energy storage systems or to projects established in the state until 2030, whichever comes first.
Despite the positive reception of the Rajasthan GEOA rules, ambiguities regarding OA charges remain. The regulations specify nine types of OA charges, and the category labeled “Any other charges” introduces confusion, reducing transparency and potentially impacting the long-term financial viability of projects. Although the “Additional Surcharge” does not apply to consumers already paying a fixed charge, the rules indicate that it may still apply if there is a gap in the recovery of the fixed charge and associated costs incurred by the respective distribution company (DISCOM).
The robust GEOA regulatory framework established by these rules is expected to significantly contribute to the scaling up of Rajasthan’s green open access installed capacity. Additionally, the state’s concurrent strategy to promote industrial and manufacturing growth through incentives, as outlined in the “Rajasthan Investment Promotion Scheme 2024,” will influence the future development of the green OA market within the state.
Going ahead, the Rajasthan GEOA rules will serve as a crucial foundation for shaping state-level green OA policy. Consequently, future amendments to the GEOA rules in highly industrialized states such as Maharashtra and Gujarat are likely to include specific mandates related to energy storage systems (ESS). These rules highlight the essential role that ESS is set to play in India’s expanding Commercial & Industrial (C&I) sector, thereby supporting India in achieving its long-term renewable energy and decarbonization targets.