Maharashtra MYT 5th order: what changed for open-access in 2026
The 5th MYT order shifted banking from a 20-hour to an 8-hour window, redefined Time-of-Day slots, and tightened the captive policy. ZGDI's plain-English read for procurement teams using open access.
- Maharashtra's 5th MYT order (effective April 2025) replaces the 4th MYT TOD slots with a new structure: TOD A (00–06), TOD B (06–09), Solar Hours TOD C (09–17), Peak Hours TOD D (17–22).
- Banking withdrawal window cut from 20 hours to 8 hours — banked energy can only be withdrawn within specific time slots.
- Captive policy 2026 amendments retain the 26% equity and 51% consumption rules, but tighten group-company definitions, SPV treatment and proportionate consumption rules.
- MSEDCL HT-I energy charges have risen to ₹8.68/kVAh in 2025–26, up from ₹7.51 in 2021–22 — strengthening the open-access savings case despite tighter banking.
What the 5th MYT order changed
Maharashtra moved from the 4th MYT regime (in force to March 2025) to the 5th MYT regime (April 2025 onwards). The change is meaningful for any open-access user with a renewable generation portfolio in the state — particularly users relying on banked energy to bridge intermittency.
Time-of-Day slots, redefined
The 4th MYT had four labelled slots — Off-peak (Night), Off-peak, Peak (Morning), Peak (Evening) — applied across the day. The 5th MYT replaces this with a four-tier structure tilted to renewable generation reality:
- TOD A · Normal: 00:00–06:00
- TOD B · Normal: 06:00–09:00
- TOD C · Solar Hours: 09:00–17:00
- TOD D · Peak Hours: 17:00–22:00 (and 22:00–24:00 continues as off-peak night)
Banking: 20-hour to 8-hour window
Under the previous mechanism, surplus generation banked in one slot could be withdrawn across a 20-hour window. Under the 5th MYT, withdrawal is restricted to a narrower set of slots tied to when the banking occurred: banking during Solar Hours can only be withdrawn during Solar Hours; banking during Off-Peak Night can only be withdrawn in Off-Peak Night. The effective banking window collapses from 20 hours to roughly 8.
The objective stated by the Commission: encourage open-access users to adopt BESS, mitigate the supply-demand imbalance from increasing solar penetration, and improve grid reliability through self-regulation. The mechanical effect on a procurement team: banking-window arbitrage is largely gone, and contractual block shape becomes more important than aggregate volume.
“Banking is no longer a buffer you can rely on. Either you size your generation to the load shape, or you put BESS on the asset. There is no third option.”
Captive policy: 2026 amendments
The 2026 captive policy amendments retain the headline 26% equity and 51% consumption rules — but tighten almost every other definition around them:
- Captive user now explicitly includes consumption via ESS.
- Group companies (holding, subsidiaries, fellow subsidiaries) treated as a single captive user.
- Ownership definition includes indirect ownership via group structure.
- SPVs explicitly defined as single-purpose entities and treated as AOPs.
- Proportionate consumption rule clearly defined — consumption is capped to proportionate ownership, with an exception for users holding ≥26%.
- Mid-year shareholding changes use weighted-average shareholding.
- Verification: same-state by state nodal agency, multi-state by NLDC.
- Failure of captive status now triggers CSS/AS plus LPS-based carrying-cost interest.
Tariff trend: still rising
The MSEDCL HT-I energy charge has risen every year for five years: ₹7.51 (FY21–22) → ₹7.74 (FY22–23) → ₹8.12 (FY23–24) → ₹8.41 (FY24–25) → ₹8.68 (FY25–26). The open-access savings case versus the DISCOM tariff has strengthened despite the banking changes — the gap to a hybrid-block tariff has widened, not narrowed.
What procurement teams should do
Three practical implications. One: re-model existing PPAs under the 5th MYT banking rules. If the original sizing assumed the 20-hour banking window, the realised tariff will differ. Two: ask the developer for the contractual block shape — flat, load-following, or solar-hours-shaped — rather than annual generation volume. Three: budget for BESS. Under both the 5th MYT incentive structure and Maharashtra's RE policy, BESS is increasingly less optional.
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